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EDGE/AACRAO, which USCIS considers a reliable source, identifies a five-year physical therapy bachelor's degree from the Philippines as equivalent to a U.S. baccalaureate. The FCCPT evaluation cannot establish single-degree foreign equivalency to a U.S. master's because it aggregates credits from multiple sources and used an outdated CWT version with lower minimum requirements than CWT 4 (69 vs. 90 professional education credits), and the beneficiary only has 86.25 professional education credits under CWT 4. The petitioner failed to rebut the EDGE findings or show the beneficiary's degree differs from other Philippine five-year PT programs.

AAO found FCCPT's coursework-aggregation methodology cannot establish that the beneficiary's single degree is above a baccalaureate, while EDGE characterizes the Philippine BSPT as comparable to a U.S. bachelor's degree. The petitioner did not establish five years of progressive post-baccalaureate experience.

FCCPT's methodology evaluates aggregate coursework from multiple sources rather than whether the beneficiary's single degree is the foreign equivalent of a U.S. master's degree, making the FCCPT evaluation an improper basis for the advanced-degree determination. EDGE/AACRAO data shows the Philippine five-year Bachelor of Physical Therapy degree is equivalent to a U.S. baccalaureate. The petitioner's own documents (CAPTE, APTA Fact Sheet, NCES) undercut rather than support FCCPT's 150-credit threshold for a master's degree. The petitioner has not shown the beneficiary holds a single foreign equivalent degree above a baccalaureate or the foreign equivalent of a master's degree in physical therapy.

AAO disagrees with the director: the TESOL master's is not academically appropriate to teaching Korean or advising Korean students, and the petitioner has not shown her Korean teaching certificate is equivalent to a U.S. advanced degree, nor that her intended advisory work qualifies as a profession.

AAO found that inapplicability of labor certification due to self-employment cannot alone justify a national interest waiver, that the petitioner's future consultant/NGO plans were not established at the time of filing, and that her local teaching record did not demonstrate national-scale achievement. The petitioner also improperly attempted to materially change the basis of the petition after filing.

AAO found that the petitioner's achievements were local to her school, that the school's recognition was attributable to the institution and its PLC process rather than to the petitioner individually, that the video materials reflected the book author's innovations rather than the petitioner's, and that unimplemented proposals and future plans could not satisfy the national scope prong.

Because the FCCPT evaluation does not assess single-degree equivalency to a U.S. master's degree in physical therapy but rather aggregates credentials, and because EDGE identifies the Philippine bachelor's degree as a baccalaureate-level credential, the beneficiary has not demonstrated the foreign equivalent of the U.S. master's degree in physical therapy required by the ETA Form 9089.

The AAO agreed that the petitioner's research area is national in scope, consistent with the director's finding.

The AAO agreed with the director that the petitioner's work in researching demyelinating neurological diseases has substantial intrinsic merit, noting that the witness letters addressed the importance of the research area.

The AAO found the petitioner's citation record sparse as of the filing date (only two independent citations documented), his grant funding did not prove field-wide influence, and his witness letters failed to distinguish his contributions from those of others studying the same problems. The AAO also noted that mastering advanced techniques invented by others and performing routine professional activities like publishing and seeking grants do not establish NIW eligibility.