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Digital Transformation Strategist
Colombo & Hurd secured approval of an EB-2 National Interest Waiver (NIW) petition for a digital transformation expert from Jamaica after a successful response to a Request for Evidence (RFE). The petition showed that the client’s work, helping small and medium-sized enterprises (SMEs) across the United States modernize their operations and improve efficiency, carries national economic significance far beyond any single client or employer.
Small businesses make up 99.9% of all U.S. businesses and employ nearly half of the American workforce. Yet many of them still rely on outdated systems and manual work that slow operations and increase costs. These technology gaps make it harder for many businesses to grow and compete.
Our client spent her career closing those gaps. Her proposed endeavor focuses on building a replicable digital operating framework that gives SMEs across the country the tools, systems, and workforce skills to modernize sustainably, not just adopt technology temporarily.
This case study explains how Colombo & Hurd built the petition and responded to the RFE to secure approval. The petition was filed by Colombo & Hurd Senior Attorney Vivian Daher.
A Career Built at the Intersection of Technology, Business, and Education
Our client holds a bachelor’s degree in computing and information technology, a master’s degree in information systems, and a Ph.D. in accounting and information systems. For over a decade, she has published research on how organizations adopt and use technology and how small enterprises navigate technological change.
Our client has served as an Assistant Vice President at a major financial services group, where she led technology modernization projects and oversaw system migrations that improved operational efficiency. She has also conducted research for national labor reform commissions and lectured at multiple universities.
In the United States, she intends to design, pilot, and deploy a standardized Digital Operating Framework tailored specifically for SMEs. Her system would help small businesses modernize their operations through better processes, employee training, and long-term technology planning.
Demonstrating That a Framework Built for Individual Clients Has National Impact
After the initial petition was filed, USCIS issued an RFE. The officer raised two central concerns.
First, whether the proposed endeavor had national importance, finding that the work appeared to serve individual SME clients rather than address a challenge of national scale.
Second, USCIS appeared to treat the client’s proposed employment as a Digital Modernization Strategist as the endeavor itself, rather than recognizing it as the vehicle through which a broader, nationally significant framework would be built and deployed.
Clarifying the Long-Term Goal of the Work
The RFE response addressed both concerns directly.
To clarify the distinction between proposed employment and proposed endeavor, the attorney explained that the client’s consulting work supported her larger long-term goals. The actual endeavor is the creation of a standardized, transferable, evidence-based methodology: a Digital Operating Framework that any SME, in any industry, in any region of the country, could adopt. The framework itself, not the individual consulting engagements, is what carries national significance.
To address the national importance concern, the response showed how her work aligned with federal efforts to improve digital adoption among small businesses, including White House executive directives on AI adoption, the Small Business Administration’s Digital Alliance initiative, and published data on the economic cost of digital underinvestment in the SME sector. It also showed that the framework addresses problems beyond software including broken workflows, undertrained staff, unmanaged data, and no roadmap for sustaining change. Handing a small business a new tool without fixing these does not work.
Finally, the response highlighted the entrepreneurial structure of the endeavor. Because the client is self-employed rather than tied to a single employer, the response emphasized the strength of this flexibility. It is precisely what allows the framework to be developed, tested across multiple business environments, refined through real-world pilots, and ultimately scaled nationally.
The model plan submitted with the RFE response was comprehensive and specific. It included a detailed five-year financial projection, employment creation estimates, and ties to Opportunity Zone communities (federally designated areas where investment is directed toward economic development in underserved populations), where the work would initially be anchored.
USCIS approved the EB-2 NIW petition following the RFE response. Our client can now move forward in the process toward permanent residence, while continuing her work helping small businesses improve their operations through better digital systems and long-term planning.
| Category | Details |
| Visa Classification | EB-2 National Interest Waiver (NIW) |
| Nationality | Jamaica |
| Professional Field | Digital Transformation / SME Modernization |
| Education | Bachelor’s degree in computing and information technology; Master’s degree in information systems; Ph.D. in accounting and information systems |
| Request for Evidence (RFE) | Yes |
| Outcome | Approved |
| Lead Attorneys | Attorney Vivian Daher |
