Navigating the New H-1B Visa Requirements: Key Considerations for GME Leaders

On September 21, 2025, a new presidential proclamation went into effect requiring a $100,000 fee for many new H-1B visa petitions filed on behalf of individuals outside the United States. Although the policy was introduced in response to concerns about misuse of the H-1B program in the tech and outsourcing sectors, it’s broad application may have far-reaching implications for the U.S. healthcare workforce, particularly Graduate Medical Education programs that rely on H-1B sponsorship to recruit international residents and fellows.

Overview of the Policy

The new regulation applies to H-1B petitions submitted on or after September 21, 2025, for individuals outside the United States who do not currently hold valid H-1B visas. Employers must provide proof of the $100,000 payment when filing these petitions, unless they meet specific criteria for a national interest exception.

Key clarifications provided by USCIS include:

• The fee does not apply to petitions filed before the September 21 deadline or to visa holders already in the U.S. seeking extensions or amendments.

• The fee does apply to new hires currently living abroad who require consular processing to enter the U.S.

• Exception requests must meet strict criteria and be submitted prior to filing, making them a rare and resource-intensive option.

Implications for GME Programs

While the policy targets broader workforce issues, it may unintentionally affect academic medical centers that depend on international medical graduates to fill essential residency and fellowship positions.

H-1B sponsorship is especially important for:

• Subspecialty fellowship programs with limited applicant pools

• Institutions in underserved or rural areas that depend on international physicians to meet patient care demands

• Hospitals seeking linguistically and culturally competent providers to better serve their various patient populations

In a healthcare system already facing physician shortages, these changes introduce additional financial and administrative complexity in the hiring and visa sponsorship process for academic medical centers and teaching hospitals.

How Germane Solutions Can Help

At Germane Solutions, we understand that policy changes like these can impact recruitment, workforce planning, and long-term GME strategy. We are actively monitoring the implementation of this policy to assess its effects on GME institutions nationwide.

If your program currently sponsors or is considering sponsoring international medical graduates, our team is here to help you navigate these evolving requirements. From regulatory awareness to strategic planning, we partner with GME leaders to ensure your programs remain compliant, mission-driven, and prepared for the future.

If you have questions about how this policy may affect your program, contact us to learn how Germane Solutions can support you.