September 24, 2026

Re: Fee for Certain H-1B Petitions (Docket No. USCIS-2026-0298)

Dear Director Edlow:

The Medical Group Management Association (MGMA) appreciates the opportunity to submit the 
following comments in response to the Fee for Certain H-1B Petitions proposed rule, which would 
institute a $103,265 fee for H-1B cap-subject visa petitions. With a membership of more than 60,000 
medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical 
groups comprising more than 350,000 physicians. These groups range from small independent practices 
in remote and other underserved areas to large regional and national health systems that cover the full 
spectrum of physician specialties. The H-1B visa program is a necessary tool for medical groups to 
supplement domestic workers and staff various positions of need; instituting this proposed fee would 
hinder physician practices’ ability to fill critical gaps, ultimately impacting patient access to care. We 
urge the Department of Homeland Security (DHS) to exempt all healthcare H-1B visa petitions
from this proposed fee.

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