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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.
Happy New Year and welcome back. Congress is in session this month to address, at a minimum, government funding, but there are signs that other healthcare provisions could be included if a deal comes together. It is looking less likely that extending Affordable Care Act tax credits will happen, despite a three-year extension passing in the House, while there are ongoing negotiations around funding for community health centers and reforming pharmacy benefit managers. In this month’s update, we focus on the latest on H-1B visa fees and state activities around health workforce issues.
There are growing calls for an exemption from the $100,000 H-1B visa fee for health care workers following last month’s court decision. In December, a federal court rejected a request to strike down the Administration’s $100,000 entry fee for H-1B visa holders, upholding the Administration’s authority to condition H-1B visa approval on this payment. The case heads to the US Court of Appeals for a hearing in February, but it is clear a resolution may be months away.
This is problematic for the upcoming match in March when medical students learn their residency placements. The Match relies heavily on international medical graduates (IMGs), who filled nearly 17% of program year 1 (PGY-1) positions in 2025. Without any further guidance this could affect how residency programs handle applicants who require H-1B sponsorship. It also puts more emphasis on J-1 visa pathways, since visa holders already in the country when applying for the H-1B are not subject to the fee.
Members of the New Democrat Coalition sent a letter this month to the Department of Homeland Security to exempt health care workers from a new H-1B visa fee. This is a welcome letter, but it will likely not be taken seriously by the Administration unless it is bipartisan. We are working on identifying Republicans who may be willing to lead a letter on this topic, given the mounting pressure on hospitals and other providers who rely on IMGs, not to mention the patient access concerns.
At this time, the Administration has indicated they will only consider exemptions to the fee on a case-by-case basis. AAPPR is working with other national health care stakeholder organizations on pursuing individual exemptions while also securing a broad exemption for healthcare workers. If you are navigating the H-1B process for candidates or have questions on best practices, we are ready to assist you.
It is no secret that healthcare shortages present an urgent threat to patient access. We are monitoring what states are doing to identify trends or successful efforts that can be replicated or used to leverage action at the federal level. In Pennsylvania, State Rep. Kathy Rapp, Republican Chair of the Houe Health Committee, wrote a letter to Dr. Mehmet Oz, the Administration of the Centers for Medicare & Medicaid Services (CMS), asking him to accelerate funding due to hospitals ceasing labor and delivery services. In her letter, she highlighted the Conrad 30 program as a solution to help address shortages, in addition to increasing the number of residency slots.
In Alabama, lawmakers introduced a bill to overhaul the state’s existing rural physician tax credit by increasing the annual incentive from $5,000 to $10,000. Beginnning in 2027, eligible physicians who live and practice in rural communities could receive this credit for up to four years.
In Mississippi, an article appeared in the Mississippi Independent highlighting the importance of foreign doctors across the state, and the potential risks to patient access should the H-1B fee remain in effect. It is important to see articles like this because it creates an opening to discuss with lawmakers the importance of international physicians to patient access.
AAPPR is working on a state grant program that would award grants to employers who secure a J-1 visa waiver through the Conrad 30 program, to support the recruitment and retention of that physician.
The House has passed a three-year extension of ACA premium tax credits, but Senate talks have stalled over abortion-funding (Hyde) language, leaving little room for compromise. Even if negotiators reach a deal, it would still need broad Senate support, a House vote if amended, and White House sign-off, as marketplace open enrollment ends today with initial enrollment down by 1.4 million. Lawmakers have floated extending open enrollment if a deal materializes, but with the Senate leaving town and end-of-January deadlines for other priorities, prospects are dimming by the day.
On January 22nd, tune in to hear from Sungchul Park, Associate Professor at the Department of Health Policy and Management at Korea University, to discuss healthcare workforce shortages and patient outcomes at Stanford University. He will discuss how an 18-month nationwide walkout by South Korea’s trainee doctors led to worse patient outcomes, fewer hospital and clinic visits, and higher costs per hospital stay. The study highlights how vulnerable health systems are to staffing disruptions and the need for stronger workforce resilience.
Last Updated: January 6, 2026
Just before the holidays, a federal court rejected a request to strike down the Administration’s $100,000 entry fee for H-1B visa holders, upholding the Administration’s authority to condition H-1B visa approval on this payment. U.S. District Judge Beryl Howell found that the President has broad statutory authority to regulate both immigrant and nonimmigrant entry. The Chamber of Commerce, who are leading this particular this case, requested the US Court of Appeals consider this decision and expedite its review, setting up oral arguments for February.
While additional lawsuits remain pending, including one filed by 20 states last month, the ruling marks an early validation of the policy and leaves employers facing increasing questions and pressures for a clear resolution.
We will continue to pursue a clear exemption for health care workers given the uncertainty following this latest court decision and encourage you to reach out with questions or issues as you navigate the H-1B process. You can read our two previous updates from October 28, 2025 and December 22, 2025.
Separately, the Department of Homeland Security last month finalized a rule overhauling the H-1B selection process. Instead of equal odds for all registrants, the new lottery weighs selection by wage level, granting the highest wage tiers more entries and thus better odds. The regulation will apply to the fiscal year 2027 registration period, meaning petitions filed before that date will follow the current lottery rules. The wage-weighted lottery will tilt selection toward higher-paying roles and employers, potentially undermining entry-level or lower-paid clinical positions. While some employers may be cap-exempt and outside the lottery, these pressures will likely shift recruiting strategies and priorities in the new year.
We will cover this change in more detail in the January legislative update but encourage you to reach out with any questions in the meantime.
Last Updated: December 22, 2025
For more background on this policy, review our previous update HERE.
On December 19, 2025, U.S. District Judge Beryl Howell heard from the U.S. Chamber of Commerce and Association of American Universities in their case challenging the Administration’s $100,000 fee on new H-1B visas. During the court proceeding, Judge Howell questioned the employer groups to demonstrate that the Administration is violating federal law, noting the President has broad powers to regulate immigration, including restricting entry of foreign workers.
While employers argued that the policy is disrupting recruitment plans for employers, Judge Howell sought to better understand how the groups are impacted by the policy, when the impact is more directly felt by prospective H-1B candidates. The Justice Department argued that the Administration is permitted to add preconditions to entry without consulting Congress.
While this would appear to be a setback, there have been other developments ratcheting up pressure on the Administration over this policy. This month, 20 states joined together to sue the Trump Administration over this policy, with California Attorney General Rob Bonta arguing that the Administration cannot rewrite immigration law. A broad coalition of schools and health providers also submitted two legal filings in federal court against this policy this week. This comes on the heels of an initial lawsuit led by a nurse staffing company challenging the Administration’s H-1B restrictions this fall.
Since Judge Howell did not offer any concrete timeline for a decision, we are continuing to work with national health stakeholders and Congress to urge the Administration to exempt health workers from the fee. Several members of Congress have reached out to the Administration call for an exemption, and we will continue to seek more outreach until we get a definitive response from the Administration.
AAPPR is exploring whether there is a viable path to relief that leverages the national interest authority with targeted congressional engagement. The Administration’s proclamation states that the Department of Homeland Security could waive the $100,000 fee if it determines the hiring of that H-1B worker is in the national interest and does not pose a threat to national security. That national interest standard provides a practical avenue for employers to seek tailored relief where the fee would impair continuity of care, exacerbate shortages, or otherwise impede access for patients.
AAPPR is already working with hospitals that have submitted H-1B applications and require letters of support highlighting the national interest standard as justification for waiving that fee. We can support your organizations with a similar letter or work with you to engage your Congressional delegation for a similar letter of support. Congressional engagement would be at its most beneficial when requesting an exemption from the fee.
Please share this with your legal counsel if you are encountering candidates eager to move forward or your organization is ready to pursue this pathway given the continuing uncertainty. We are happy to answer any questions.
For more information on this H-1B policy, you can review our last update here.
Congress is close to wrapping up the legislative session for the year. Despite intense focus on health care costs and Affordable Care Act (ACA) tax credits, the drive for consensus has been bumpy and unproductive. After two failed votes in the Senate that would have extended the tax credits, the House GOP is trying to chart a path that appeases moderates key to their majority without upsetting the more conservative wing of the party. Lawmakers are also trying to pass appropriations packages, an effort to make some progress before the end of the year, with the next funding deadline just seven weeks away.

AAPPR’s CEO Carey Goryl and Policy Advisor Eli Greenspan visiting the congressional offices in Washington D.C.
AAPPR’s CEO Carey Goryl and Policy Advisor Eli Greenspan braced the December chill to meet with congressional offices this month. They introduced offices to AAPPR’s mission, membership, and the current state of physician recruitment and retention. It was a great opportunity to highlight our federal priorities, meet with staff to learn what they are hearing about these issues, and how we may be able to partner to improve the physician pipeline considering numerous challenges impacting this field and patients. Carey and Eli met with bipartisan offices from Michigan, Florida, North Carolina, New Jersey, California, and Ohio, with more follow ups into 2026.
This engagement is key to our growing presence in Washinton DC and identifying partners on Capitol Hill positioned to advance issues important to provider recruitment and health care delivery.
As you are likely aware, the Department of Education plans to phase out Grad PLUS and set new loan limits starting July 1, 2026. There will be two caps: up to $20,500 per year (and $100,000 total) for most graduate programs, and up to $50,000 per year (and $200,000 total) for certain “professional” programs.
“Professional” will cover a short list of fields—medicine, dentistry, law, pharmacy, veterinary medicine, optometry, osteopathic medicine, podiatry, chiropractic, theology—and licensure‑leading PsyD/psych PhD programs. It will not include physician assistants, advanced practice registered nurses/nurse practitioners, occupational therapy, or other licensed health programs, meaning many students in high‑need fields could face federal loan limits below typical program costs.
The Department still has to publish a proposed rule (expected in early 2026) with ~30‑day comment period. The new limits would apply only to new federal borrowers after July 1, 2026; current borrowers keep their existing terms. AAPPR is closely monitoring this issue and welcomes your feedback if you have questions or concerns about this policy issue.
In September, the President instituted a policy that imposes a $100,000 fee on certain new H-1B petitions. The fee applies primarily to new H-1B applications who are coming from abroad, but the policy and lack of clarity has had significant effects on the healthcare industry, leading to many institutions simply pausing recruitment of H-1B physicians.
We will be publishing a new update this month, but oral arguments have been scheduled in the U.S. Chamber of Commerce and the Association of American Universities case against the Trump Administration, for December 19th. The plaintiffs have argued that the Trump Administration does not have unlimited authority to set fees.
If the court rules against the Administration, it could provide much needed clarity for health recruiters. Stay tuned for more updates this month.
While on Capitol Hill, Carey and Eli had several productive meetings on Capitol Hill which focused, among other things, on ways to advance the Conrad 30 legislation. The Conrad 30 legislation would extend the program for three years, improve the process for obtaining a visa, and allow for the program to be expanded beyond 30 slots if certain thresholds are met. It also would make the program more attractive to employers and prospective J-1 waiver candidates. We encouraged offices to not just work with us to build support for the legislation, but to explore attaching the bill to an appropriations bill or other moving vehicle. It will be difficult to overcome limited Republican opposition in this current environment, but we were pleased that offices were receptive to a more action-oriented approach to elevating this important issue.
In addition, as we have pointed out in recent months, we are moving closer to seeing the introduction of new legislation that could help boost recruitment of J-1 candidates in lower utilizing states. The idea is that J-1 candidates who miss out on waiver opportunities can opt in to a portal that facilitates information sharing between states with available slots and employers who need help filling gaps in their primary care or specialty workforce. This is an exciting development highlighting the importance of engagement and education to highlight AAPPR’s unique perspective when it comes to healthcare delivery.
Dr. Scott Gottlieb, former FDA Commissioner, published a piece in JAMA on artificial intelligence titled, “How AI Will Help Solve Medicine’s Productive Challenges.” This is worth reading because it shows how smarter AI, clearer FDA rules, and better Medicare payment policies could safely automate routine tasks, improve outcomes, lower costs, and fairly reward doctors.
Thank you for reading throughout 2025 and your continued engagement on policy and advocacy. Looking forward to building on our successes in the new year.
Physician and provider recruitment shortages continue to challenge health systems nationwide, particularly in rural and underserved communities. International medical graduates (IMGs) who train in the U.S. under J-1 Visas and later pursue waivers to remain and practice in the country, play a critical role in bridging these care gaps. As the 2025-2026 Conrad J-1 waiver cycle begins, recruiters are navigating new variables that could shape their strategies for the year ahead.
While the core structure of the Conrad 30 Waiver Program remains steady, recent policy discussions and operational factors have added complexity. Recruiters must balance short-term adjustments like potential changes to filing fees and government processing risks with long-term awareness of legislation that could reshape the landscape entirely. Staying informed and proactive will be key to ensuring continued access to qualified candidates and supporting communities that depend on them.
What’s New This Year?
The 2025-2026 season brings both stability and uncertainty to the J-1 Visa waiver process. The most notable development involves a proposed $100,000 filing fee for certain H-1B visas, which could directly impact organizations leveraging foreign-trained physicians. . Though the proposal has been narrowed since its release, its potential cost implications underscore the importance of keeping a close eye on policy updates and maintaining advocacy engagement.
At the operational level, there have been no significant changes in state-level allocations or specialty demand. Recruitment professionals can continue to reference AAPPR’s 2025 Benchmarking Report to stay up to date on the most common physician searches to guide strategic focus toward high-need specialties.
Despite these challenges, recruiters should continue leveraging J-1 pathways, communicate reassurance to candidates and avoid pausing efforts amid uncertainty. This steady approach helps sustain interest among IMGs while strengthening organizational readiness for any upcoming changes.
What Do Recruiters Need to Know?
Amid the shifting policy environment, the most effective recruitment strategy remains a steady, coordinated approach. Success with J-1 waivers depends on the entire organization, not just the recruiter. Legal, human resources and clinical leadership teams all play roles in ensuring a smooth and timely onboarding process.
Recruiters should emphasize internal buy-in early in the cycle. When organizational leaders understand the long-term value of J-1 hires, especially for hard-to-fill positions, they are more likely to allocate the time and resources needed to support the process. This preparation can be the difference between securing a waiver slot and missing one due to documentation or timing issues.
Common challenges persist across the industry, including competition for limited waiver slots, strict timelines and variable state requirements. To overcome these:
Understanding the dynamics of J-1 waiver recruitment doesn’t just improve immediate hiring success, it also strengthens organizational resilience. Recruiters who remain proactive and informed help their institutions stay competitive in a constrained labor market while advancing access to care across underserved communities.
Looking Ahead
Long-term policy developments could bring positive change to the J-1 landscape. The Conrad State 30 and Physician Access Reauthorization Act aims to enhance program incentives and make participation more attractive for employers. If passed, this legislation would provide clearer pathways and potentially expand opportunities for IMGs seeking to continue practicing in the U.S.
Recruitment professionals should remain in close contact with both their internal teams and AAPPR, which continues to monitor these evolving issues. Staying informed through reliable channels and connected with peers across the country ensures organizations can adapt quickly to new regulations or eligibility criteria in the coming years.
The J-1 Visa Waiver Program remains one of the most effective tools for addressing persistent physician shortages, but it demands foresight and collaboration to navigate successfully. This year’s environment may bring uncertainty, but it also offers opportunity. Recruiters who stay informed, plan early and engage organizationally will be best positioned to meet workforce needs while contributing to broader access to care.
AAPPR encourages members to remain active participants in this evolving conversation:
By working together and staying engaged, AAPPR members can help shape a more stable, sustainable and equitable future for healthcare recruitment.
To learn more about AAPPR’s government affairs efforts, please visit www.aappr.org/government-affairs. If you are interested in becoming an AAPPR member, please visit www.aappr.org/join-now to learn more.
The federal government is open again after a 43‑day shutdown. It is the longest shutdown in U.S. history, and the deal to reopen the government failed to resolve the key issue raised by Democrats: the expiring Affordable Care Act (ACA) tax credits. The deal extended funding through January 30, 2026, giving Congress just over two months to pass FY26 appropriations bills and address pending policy items, which include several major health policies beyond the ACA credits, such as telehealth flexibilities. The sharp increase in health costs will also be a topic of intense debate. We cover this and more in the November update below.
As you are aware, the President’s proclamation, “Restriction on Entry of Certain Nonimmigrant Workers,” imposes a $100,000 fee upon applying for an H‑1B visa. This proposal jolted the healthcare industry, given international medical graduates are critically important to upholding healthcare access, and it will make staffing more challenging.
As it currently stands, most healthcare hires changing status in the U.S. are not subject to the administration’s $100,000 fee under current guidance. This includes residents and fellows moving from J‑1 or F‑1 to H‑1B, as well as H‑1B extensions and transfers. However, the fee still applies to new H‑1B hires coming from abroad.
We have been working with congressional offices on a letter to the administration that would exempt all healthcare providers from the fee. Only four percent of approved H‑1B workers were in medicine or health occupations, meaning exempting such providers would not upend the broader policy aims. We appreciate congressional offices weighing in on this important issue and will continue to encourage offices to reach out to ensure this policy does not place undue constraints on healthcare recruitment.
As part of the deal to reopen the government, Senate Republicans agreed to a vote on a one‑year ACA subsidy extension in mid‑December. There is no guarantee this will pass the Senate, but a growing number of members realize the pitfalls of letting the tax credits expire without a clear path forward.
In fact, a small but key group of moderate House Republicans would like to help the Senate craft an ACA subsidy extension that can also pass the House. The challenge is that the majority of House Republicans are against extending the subsidies without significant changes. While there are risks for Speaker Johnson in jamming House Republicans on this vote, most lawmakers and observers recognize that rising health costs are a bigger risk to their majority than a short‑term extension of the tax credits.
We will continue to monitor the debate on extending ACA tax credits, as well as discussions of a broader health reform package.
Last month, CMS finalized separate payment rate updates for 2026 under the Medicare Physician Fee Schedule. Physicians in value‑based models (APM “Qualifying Participants”) will have a conversion factor increase of 3.77%, and other clinicians will have a conversion factor increase 3.26%. In plain terms, this means modest across‑the‑board increases intended to support access to care.
AAPPR advocated for more predictable, sustainable payment updates and highlighted downstream workforce impacts in its comment letter to the proposed rule.
Last month, AAPPR hosted a webinar on the upcoming Medicaid changes contained in the One Big Beautiful Bill Act. The webinar unpacked the policy implications—from Medicaid redeterminations to provider taxes—and what states and health systems should expect. You can listen to the webinar by clicking here: You can listen to the webinar by clicking here.
We’ll continue to share updates and track developments on this pivotal issue as we head into 2026.
When a physician signs a contract, in-house physician and provider recruiters may breathe a sigh of relief and shift their attention to one of the many other searches they are likely managing. However, a new study from Jackson Physician Search and the Medical Group Management Association (MGMA), “From Contract to Connection: How Authentic Relationships Foster Early-Career Loyalty and Retention,” reveals that this hands-off approach may be undermining long-term retention efforts. While 69% of administrators expect new physicians to stay six or more years, more than half (59%) of physician respondents reported leaving their first job within three years.
The report explores the factors driving new physicians to leave their first jobs so soon (spoiler alert: compensation doesn’t top the list), and while the reasons are complex, some of the solutions are surprisingly simple. For example, the study reveals that the pre-boarding phase—the median 180 days between signing and starting—is one of the most influential periods for building a foundation of loyalty and engagement. So, rather than stepping back after the contract is signed, recruiters must step up to ensure the relationship continues to grow during this critical window.
The in-house recruiter is uniquely positioned to serve as the consistent thread connecting all pre-boarding touchpoints. After all, recruiters have already established rapport during the search process. Candidates trust them. They know how to reach them. The relationship already exists; it simply needs to be intentionally sustained. Keep reading as we explore exactly what this looks like.
The Jackson Physician Search and MGMA report identifies a “loyalty formula” centered on respect and communication, fair workload policies, and compensation with clarity. As the recruiter, you can model that formula during pre-boarding and ensure the new hire experiences it from day one.
Within 24 hours of contract signing, send a personal message that goes beyond congratulations. Acknowledge the significance of their decision, reaffirm why they’re a great fit, and outline what they can expect in terms of communication frequency and next steps. If you will not be their primary contact, let them know who they will be hearing from going forward and reinforce that you will remain accessible to them throughout the transition.
The study found that regular check-ins—even brief ones—significantly improved physician preparedness and cultural alignment. In the report, 76% of physicians who received weekly communication rated their pre-boarding experience as “excellent” or “good” compared to 24% who received communication rarely. Those who received weekly or monthly communication reported feeling more prepared for the non-clinical aspects of the job.
Create a communication calendar that includes weekly emails during the first month, transitioning to bi-weekly touchpoints. Schedule monthly phone or video calls to address questions and maintain a personal connection, and be sure to communicate key events, such as credentialing completion or the 30-day countdown to the start date. Consistency matters more than length. A five-minute call every two weeks builds more trust than a single hour-long conversation three months before the start date.
More than two-thirds of physicians in the study said peer relationships were the most influential factor in their decision to stay. Recruiters can facilitate these early connections by arranging informal virtual coffee meetings with future colleagues, sharing team rosters with brief bios, coordinating pre-start shadow days or site visits, and creating opportunities for the new hire’s family to connect with other physician families in the community. Your role is to orchestrate these touchpoints, not necessarily to be present for each one. Follow up afterward to ensure they happened as planned and were a valuable use of time.
New physicians are simultaneously navigating credentialing, licensing, relocation, and life transitions. They also may be making decisions about schools, housing, and spousal employment. While they may not ask for help with these matters, offering resources demonstrates that the organization understands and cares about them as people, not just providers. Create a resource package that includes moving company recommendations, school district information, spouse career resources, local physician testimonials, and answers to common logistical questions. Share this early in the pre-boarding process, then check in periodically to see if they need additional support.
Credentialing, IT setup, and compliance requirements are necessary but notoriously frustrating. Rather than simply forwarding emails from other departments, add context and empathy. Explain why each step matters, provide realistic timelines and who to contact with issues, acknowledge when processes are cumbersome, and check in when you know they’re waiting on approvals. Simple messages like “I know credentialing feels like a black hole—I checked in with the team and your application is moving along as expected” can prevent anxiety and demonstrate that someone is watching out for them.
Pre-boarding isn’t just a “nice-to-have.” Research shows it’s a strong predictor of long-term engagement. Every interaction between signing and day one either builds trust or erodes it. Of course, recruiters are already juggling multiple responsibilities, and may not have the bandwidth to develop and manage a high-touch pre-boarding program. The data in the new report will help you make the case for investing time in this process. If you need to outsource less critical tasks or expand your capacity with a physician recruitment partner, the impact of pre-boarding on retention makes it a strategic imperative.
When you show up consistently during pre-boarding, you 1) validate the candidate’s decision to choose your organization over others, 2) model the communication and respect they can expect from leadership, 3) surface and address concerns before they become reasons to reconsider, and 4) build a foundation of trust that will carry through into their first years.
Consider developing a formal pre-boarding program that includes:
The recruitment process doesn’t end at contract signing—it extends through the entire pre-boarding period. In-house recruiters have both the skills and the relationships to ensure this critical window becomes a competitive advantage rather than a missed opportunity.
By maintaining consistent, personal, strategic communication during pre-boarding, you transform your role from talent finder to retention champion. You prove that the organization does what it says it will do. And you give every new physician a powerful reason to stay, long before they see their first patient. If we hope to lengthen the average tenure for early-career physicians, the 180-day investment in consistent pre-boarding communication isn’t optional—it’s essential.
Last Updated: October 28, 2025
Effective September 2025, a new policy imposes a $100,000 fee on certain new H-1B petitions. The H-1B visa allows companies to temporarily hire nonimmigrant foreign workers for certain roles, such as computer-related software development, architecture, engineering, and healthcare, among other fields. Computer-related technology jobs make up the majority (64%) of all H-1B visas issued, compared to just 4% in the healthcare sector in FY2024.
As of October 21, 2025, most healthcare hires changing status inside the U.S. (e.g., residents/fellows moving from J-1 or F-1 to H-1B, or H-1B extensions/transfers) are not subject to this fee under current guidance. The fee would apply primarily to new H-1B hires coming from abroad.
H-1B physicians keep doors open in communities where recruiting is hardest. A $100,000 fee on new petitions would sideline hires that hospitals and practices cannot afford, leading to longer vacancies, reduced services, and longer waits for patients. With demand rising faster than we can train new doctors, this policy deepens shortages and pushes costs higher for everyone.
– 64% of foreign-trained physicians practicing in Medically Underserved Areas or Health Professional Shortage Areas in 2021.
– Over the last 25 years, nearly 23,000 H-1B physicians worked in underserved communities.
– The average economic output generated by each physician nationwide is $3.2 million.
As of October 21, 2025, federal guidance says the $100,000 fee does not apply to people who are already living in the United States when you file. That includes amendments, changes of status, and extensions. It also does not apply if those same individuals later travel abroad for visa stamping or re enter on a valid H-1B based on the approved petition.
In practical terms, employers do not pay the fee for most in country cases—such as international medical graduates finishing residency or fellowship and changing to H-1B, or current H-1B employees extending or transferring.
The fee does still apply to new H-1B hires who are outside the United States and need to come to the U.S. to start work or training.
AAPPR is working with lawmakers and national health stakeholders to request the Department of Homeland Security issue clarifying guidance that all H-1B trainees and physicians should be exempted from this fee. While there have been media reports that all physicians might be exempt from this new, higher H-1B filing fee, this has not yet been confirmed and this latest guidance did not fully alleviate concerns from the healthcare sector.
There are two lawsuits challenging the proclamation which are currently ongoing in federal court. Global Nurse Force v. Trump alleges the Administration exceeded its authority under Section 212(f) and 215(a) by imposing the $100,000 fee. The second suit – Chamber of Commerce v. Department of Homeland Security – alleges the Administration exceeded its lawful authority by imposing this fee on the H-1B program that are typically set by Congress or through notice-and-comment rulemaking. Both cases are expected to play out over several months leading to uncertainty for employers.
There have been numerous reports of health systems and hospitals pausing their recruitment of H-1B physicians. This is an unfortunate, yet understandable response to this higher fee on H-1B visas, which most healthcare organizations cannot absorb. The consequences of longer hiring timelines or, worse, cutting back services will directly and negatively harm patients. AAPPR encourages your organizations to reach out with any questions or concerns with the proposal or interest in engaging at the federal level to info@aappr.org.
Please share this update with your internal teams and legal counsel who are navigating this issue for your organizations. We will continue to provide updates and are available to answer any questions or partner on ways to elevate this important issue and the significant disruption it will cause to health organizations.
The government shutdown is taking up all the oxygen in Washington D.C. as it stretches now into the third week of October. Democrats are making this shutdown about the expiring Affordable Care Act premium tax credits, which have helped millions of Americans maintain health coverage the last five years. The reality of this shutdown is that it is about the minority party seat at the negotiating table. This is a fundamental issue and a concern that goes back to the early days of the Republic. We will spare you the history lesson today, but you can read more about these latest political dynamics by clicking here.
Once the government reopens, there will be a flurry of activity on the legislative and regulatory side, including finalizing rules on Medicare payment for 2026 and addressing the lapsed authorization for various Medicare programs, including telehealth flexibilities.
Last month, President Trump signed a proclamation imposing a $100,000 fee for each new H-1B visa, arguing the new fee will encourage companies to hire more American workers. The H-1B program allows employers to hire nonimmigrant foreign professionals in specialty positions, and is used successfully by health systems, hospitals, and other health settings to address acute workforce shortages in areas that struggle to recruit American health workers.
The proposal set off immediate pushback, with concerns from hospitals that such a fee would be uniquely disadvantage the health industry, or worse, stop the recruiting of H-1B physicians with no suitable short-term alternative. We have joined stakeholders and Members of Congress highlighting the need for exemptions for the health care sector.
A lawsuit was filed by a group of unions and other organizations earlier this month challenging the decision to charge $100,000 fee, highlighting the disruption is far wider than just health or tech. We will continue to closely monitor this case and provide updates on this issue.
We have had discussions with congressional offices and other stakeholders this summer about ways to improve the Conrad 30 program. The Conrad 30 program grants each state 30 waivers each year to recruit international medical graduates (IMGs) completing their medical residency program on a J-1 visa. As a condition of their visa, these IMGs must practice in a rural or underserved area for at least three years. Each state may use up to 10 ‘flex’ waivers for sites outside designated shortage areas, provided those sites serve patients who reside in underserved areas.
We have discussed targeted flexibility for rural and other low utilization states that routinely use all 10 flex waivers but do not reach their overall cap of 30. Allowing such states a limited number of additional flex waivers the following year would better align the program with the realities of sparsely populated regions and persistent provider shortages.
We will continue to explore and discuss other flexibilities to strengthen this program and improve recruitment and retention of physicians. Please reach out if you have any ideas or questions!
AAPPR is continuing to advocate for improving Medicare reimbursement long-term, increasing the number of Graduate Medical Education (GME) slots, and improving the pipeline of physicians through leveraging international medical graduates (IMGs).
These latest announcements around changes to the H-1B program present serious obstacles, but they are being challenged in court while we and other stakeholders pursue carveouts for the healthcare industry. All this attention on how this impact the health care workforce is an opportunity to educate policymakers and others about the reality of confronting health workforce shortages. We will continue to elevate these issues and ensure our collective voices are heard.
Stay tuned for more updates across these issues.
Last week, Senators Dick Durbin (IL) and Kevin Cramer (ND) re-introduced the Healthcare Workforce Resilience Act. HWRA would recapture up to 40,000 previously authorized but unused visas, allocating 25,000 for nurses and 15,000 for physicians. These visas would not be subject to per-country caps and would be issued based on priority date. This bill aims to help address nursing shortages across the country and assist doctors who are already practicing in the U.S. but have been affected by the green card backlog for over a decade.
AAPPR endorsed the legislation and a quote from Chief Executive Officer Carey Goryl was included in the press release and subsequent press. You can view the press release by clicking here.
Last month, Senators Joni Ernst (IA) and Amy Klobuchar (MN) re-introduced the DOCTORS Act. The DOCTORS Act requires states to report their unused physician waiver slots each year. The Secretary of State will total these unused waivers and redistribute them equally among states that reached their maximum cap (30) the previous year, with the total divided by three. This process helps retain foreign physicians in the U.S. without increasing the overall number of visas.
We supported this bill because we think it would more effectively increase the total number of IMGs practicing in the U.S. via the Conrad 30 program, and are working with the sponsors of the Conrad 30 bill to include this language in the bill.
Last month, the Department of Homeland Security (DHS) proposed a rule that would drastically change the way J-1 visa status is managed for physicians. Under the proposal, J-1 physicians would be admitted for a fixed period—up to the program end date or a maximum of four years—and would be required to file separate extension applications with USCIS for any additional training, transfers, or leaves, replacing the current system of automatic renewals.
For employers, this means facing new administrative and financial burdens, as well as the risk of training interruptions and disruptions to patient care due to potential processing delays. These changes are particularly concerning given that J-1 physicians already undergo extensive vetting and monitoring through their participation in accredited training programs, making the proposed additional USCIS oversight duplicative and potentially destabilizing for the healthcare workforce.
We are closely monitoring this proposal and encourage you to reach out if you or your organizations have any questions.
AAPPR submitted comments last week to CMS on the proposed 2026 Medicare Physician Fee Schedule. This annual rule sets Medicare reimbursement rates for the upcoming year and makes other changes that impact health delivery, such as to telehealth and hospital services costs. Our comments emphasized the need for sustainable, inflation-adjusted physician reimbursement to address ongoing workforce shortages and ensure access to care for Medicare beneficiaries.
We also urged CMS and Congress to adopt permanent reforms that will help recruit and retain physicians, particularly in rural and underserved areas, and safeguard the long-term stability of the Medicare program.
We will share our comments with members and also work closely with Capitol Hill offices and stakeholders to keep this issue top of mind for congressional leadership.
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