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Why Citation Count Alone May No Longer Be Enough for an EB-2 NIW Petition

Why Citation Count Alone May No Longer Be Enough for an EB-2 NIW Petition

Published

June 23, 2026

Article Summary

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For researchers and academics pursuing an EB-2 NIW, citation count has long been treated as one of the strongest pieces of evidence in a petition package. The logic seemed clear: a high number of citations signals that peers in the field have found the applicant's work worth referencing, which suggests the contributions carry meaningful weight. For years, a strong citation record went a long way toward satisfying the second Dhanasar prong, that the applicant is well-positioned to advance their proposed endeavor.

That reading of the standard has not aged well. Adjudication patterns in 2025 and 2026 show that petitions built primarily on citation metrics are drawing more RFEs, not fewer, even when the numbers look impressive on paper. Understanding why that has shifted, and what USCIS is actually evaluating under Prong 2, matters for any applicant whose petition is currently in preparation.

What citations were originally meant to show?

Under the Dhanasar framework, Prong 2 asks whether the petitioner is well-positioned to advance the proposed endeavor. Citation count entered NIW petitions as a proxy for recognition: if other researchers have repeatedly cited your work, that suggests the field regards your contributions as significant, and by extension, that you are a credible figure capable of advancing further work in that area.

That argument still has merit. It simply no longer carries the case on its own.

Why the standard has shifted?

The January 2025 USCIS policy update, incorporated into Policy Manual Volume 6, Part F, Chapter 5, placed new emphasis on the connection between the applicant's demonstrated record and the specific proposed endeavor. The update clarified that being well-positioned is evaluated in terms of the petitioner's capacity to execute what they are actually proposing to do in the United States, not their general standing in the field at large.

That distinction is where citation-heavy petitions tend to fall short. A researcher with a strong citation record and a proposed endeavor centered on building a biotech company has not necessarily shown that their academic publication history positions them to run a commercial-stage venture. An engineer with an impressive h-index proposing to develop a clinical software product has not, through citations alone, established that they can bring that product to market. The officer's question under Prong 2 is not "has this person been recognized?" It is "has this person shown they are positioned to do this specific thing?"

The volume of NIW filings has also contributed to the shift. With approximately 63,000 NIW petitions received in fiscal year 2024, officers are reviewing far more petitions than in prior years and are better calibrated to recognize filings where the citation record is the primary argument. Petitions that follow the same structural template, strong academic record, high citation count, and letters from colleagues, are being evaluated with more scrutiny at the Prong 2 stage than they were two or three years ago.

What "well-positioned" requires beyond citations?

The most effective petitions treat citations as one data point within a broader profile of readiness, not the centerpiece. USCIS officers evaluating Prong 2 in 2026 are looking for evidence that is specific to the proposed endeavor and that shows momentum, not just past recognition.

For research-focused applicants, that means:

  • Competitive federal grant funding, such as NIH, NSF, or DOE awards, tied directly to the work being proposed

  • Invitations to peer-review journals or conference panels in the specific subfield the proposed endeavor addresses

  • Collaborations with institutions or agencies connected to the proposed work, not just to the applicant's broader research history

  • Presentations or keynote invitations where the proposed endeavor is the subject, not just the applicant's general field


For entrepreneurial and applied applicants, citations carry far less weight than traction evidence:

  • Signed client agreements or letters of intent from prospective partners

  • Funding commitments, including angel investment, competitive grants, or accelerator acceptance

  • Issued or pending patents tied to the specific product or method being proposed

  • Pilot programs, beta deployments, or contracts showing the work is already underway

Recommendation letters are a related and frequently underused opportunity. A letter that lists an applicant's citation count and describes them as a leading figure in the field does not address what USCIS needs at Prong 2. The most effective letters in 2026 come from experts with direct knowledge of the applicant's specific proposed work, who can explain why this particular applicant, rather than others in the same area, is suited to carry this endeavor forward.

What this means for petition strategy

None of this means citations should be absent from a NIW petition. A strong publication and citation record remains relevant, particularly for establishing credibility and for supporting the Prong 1 national importance argument when tied to documented federal priorities. The adjustment is in how citations are framed and what surrounds them.

A citation count presented without connection to the proposed endeavor reads as background. The same number, contextualized within the applicant's specific proposed work and supported by traction evidence and focused recommendation letters, becomes a meaningful part of the Prong 2 argument.

Applicants and practitioners still building NIW petitions around the premise that a strong academic record will carry the case are working from a framework that the adjudication environment has moved past.

Final thoughts

The shift in how USCIS evaluates Prong 2 is not arbitrary. The standard has always required positioning relative to a specific future endeavor, not general eminence in a field. What has changed is how rigorously that standard is applied and how clearly the gap shows up in RFE patterns. Applicants who anchor their Prong 2 showing to the proposed endeavor itself, rather than to their publication history, are better positioned for approval in the current environment.

Frequently Asked Questions

Do citations still matter for an EB-2 NIW petition?

Yes, but as supporting evidence rather than the primary argument. A strong citation record contributes to establishing credibility and, when connected to the proposed endeavor, can reinforce the Prong 2 showing. The problem arises when citation count is treated as a self-sufficient argument for being well-positioned. USCIS is evaluating readiness to advance a specific endeavor, not academic recognition in the abstract.

What is the most effective type of evidence for Prong 2 in 2026?

Traction evidence tied to the specific proposed endeavor. For researchers, that includes competitive grant funding, institutional collaborations, and peer-review roles in the relevant subfield. For entrepreneurial applicants, it includes signed agreements, investment commitments, filed patents, or active pilots. Evidence that shows the work is already in motion is more persuasive than evidence that documents past recognition.

How should recommendation letters address Prong 2?

Letters should engage directly with the proposed endeavor, not just describe the applicant's publication record or general standing in the field. The most effective letters come from experts with direct knowledge of the applicant's specific work, who can speak to the capacity to execute the proposed endeavor and explain why this particular applicant, not just any researcher in the same area, is positioned to carry it forward.

Does the 2025 USCIS policy update change what counts as a strong Prong 2 showing?

Yes. The January 2025 update, incorporated into Policy Manual Volume 6, Part F, Chapter 5, clarified that well-positioned is evaluated in terms of the applicant's capacity to advance the specific proposed endeavor at the time of filing, not their general recognition in the field. Petitions built around a strong academic record without connecting that record to the proposed endeavor are more likely to draw a Prong 2 RFE under the current framework.

Official Resources

USCIS Employment-Based Immigration: Second Preference EB-2: https://www.uscis.gov/working-in-the-united-states/permanent-workers/employment-based-immigration-second-preference-eb-2

USCIS Policy Manual, Volume 6, Part F, Chapter 5: Advanced Degree or Exceptional Ability: https://www.uscis.gov/policy-manual/volume-6-part-f-chapter-5

Matter of Dhanasar, 26 I&N Dec. 884 (AAO 2016): https://www.justice.gov/eoir/page/file/920996/dl

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