Exemptions urged by CDA would preserve dental schools’ ability to recruit, train qualified dentists through H-1B program

CDA also asking DHS for confirmation that internationally trained dentists meet ‘national interest’ exemption from fee
November 7, 2025
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QUICK SUMMARY: CDA is urging the U.S. Department of Homeland Security to consider exemptions to the new $100,000 fee for H-1B visa petitions from public health care employers, including dental schools, as well as federally qualified health centers and nonprofits that hire internationally-trained dentists and depend on government funding. The proclamation "would devastate rural community clinics, dental schools, and the patients who rely on them, further restricting access to essential dental care in communities that need it most,” CDA wrote Nov. 5 in a letter to the department.

CDA, in alignment with the American Dental Association, is urging the U.S. Department of Homeland Security to consider exemptions to the new $100,000 fee for H-1B petitions from nonprofit and public health care employers, including dental schools and federally qualified health centers.

The Trump administration’s proclamation “Restriction on Entry of Certain Nonimmigrant Workers” issued Sept. 19 proposed the fee for employers who recruit professionals outside the United States under the H-1B visa program to work in “specialty occupations” requiring at least a bachelor’s degree or the equivalent.

H-1B visa fee ‘would devastate rural community clinics, dental schools’

The fee applies only to petitions submitted after Sept. 25 for individuals outside the U.S. who do not yet have an H-1B visa, but CDA and ADA are stressing the untenable cost for dental schools, as well as FQHCs and nonprofits that depend on government funding. CDA is also stressing that the cost of the visa fee will ultimately harm oral health in many California communities.

“This proclamation, combined with the wage-weighted selection process in the recent proposed rule, would devastate rural community clinics, dental schools, and the patients who rely on them, further restricting access to essential dental care in communities that need it most,” CDA wrote in comments submitted Nov. 5 to Department of Homeland Security Secretary Kristi Noem.

California dental schools train disproportionate share of international graduates

Internationally-educated dentists working in the U.S. on H-1B visas address critical health care in Dental Health Professional Shortage Areas, particularly in California, which trains a disproportionate share of international dental graduates. ADA Health Policy Institute data shows that 322 (4.8%) dental school graduates nationally in 2023-24 were non-U.S. residents. That same year, 144 (45%) were enrolled in a California dental school international program. International students represented over 22% of the 648 California dental school graduates that year.

Besides providing patient care, internationally trained dentists contribute significantly as educators and complete advanced standing programs at U.S dental schools. They often go on to become U.S. citizens or permanent residents, contributing long term to the profession and to society.

A push for ‘national interest’ exemption for internationally-trained dentists

For these reasons, CDA is also asking the department for confirmation that internationally trained dentists seeking H-1B visas from abroad can qualify for the proclamation’s “national interest” exemption to the visa petition fee

Internationally-trained dentists could qualify for the exemption “due to their abilities to reduce barriers to essential health care for underserved populations, as well as to help train the next generation of American dentists,” CDA wrote. For similar reasons, nonprofit and public health care employers could also qualify for the exemption.

“CDA aligns with the American Dental Association’s recent letter in recognizing the important role of internationally educated dentists,” CDA concluded in its Nov. 5 letter to DHS.  “We believe the proposed fee contradicts the nation’s commitment to improving access to care and ultimately weakens pathways into the dental workforce. To avoid these unintended consequences for dental care and dental education, we urge DHS to consider creating exemptions to the $100k fee for H-1B petitions from nonprofit and public health care employers, including FQHCs and dental schools.”

DHS has begun assessing the H-1B visa fee. CDA will keep members updated about any changes to the visa fee structure and allowable exemptions through the weekly member newsletter, Inside California Dentistry.

Of additional interest: ADA’s letter to the director of U.S. Citizenship and Immigration Services

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