H-1B’s New “Directly Related” Rule: Focus on the Job’s Degree Requirement, Not the Person’s Degree

One major change effective January 17, 2025 is a clarification to the H-1B visa program’s specialty occupation definition. The “directly related” requirement in the new H-1B final rule has caused some confusion. In plain terms, this rule is about making sure that the field of study a job requires is logically connected to the job’s duties. In this article, we break down what “directly related” really means for H-1B jobs, how to meet this requirement, and what employers should do (with examples), all in simple language.

What Does “Directly Related” Mean for H-1B Jobs?

Under the relevant statutes and regulations, an H-1B job must be a “specialty occupation.” This means the role requires highly specialized knowledge and at least a bachelor’s degree (or equivalent) in a specific specialty as a minimum entry requirement. The new January 2025 final rule refines this by saying the degree field must be directly related to the job’s duties. In other words, there needs to be a logical connection between what someone studies in that field and what they will do on the job.

Think of it this way: if you require a certain degree for the role, the coursework and knowledge from that degree should be used in the work. For example, a software developer role might require a degree in computer science because the job involves writing code and designing algorithms, skills taught in computer science programs. On the other hand, saying “any bachelor’s degree is fine” for a highly technical job won’t fly, because a random degree (say in history or English) isn’t logically tied to duties like programming or systems design. The bottom line: a job can only qualify for H-1B if it requires a specialized degree that is directly relevant to the specific work being done.

Focus on the Job, Not the Individual’s Degree

It’s important to understand that this “directly related” test focuses on the position’s requirements – not the individual worker’s personal degree. In the past, some employers (and even some immigration officers) might have only looked at whether the beneficiary’s degree exactly matched the job. The new rule makes it clear that what really matters for determining specialty occupation is what the job itself demands. When USCIS evaluates a petition, they ask: “Does this job really require a bachelor’s degree (or higher) in a particular field, and is that field truly related to the work?” If the answer is yes, and the employer can explain why, then the job meets the specialty occupation test. It’s not about tailoring the job to the person; it’s about the inherent requirements of the job.

To be sure, the H-1B worker still needs to be qualified (they must hold the required degree or its equivalent). USCIS can and will consider a worker’s course of study to see if their education gave them the specialized knowledge for the role. However, that’s a separate analysis after establishing that the job is a specialty occupation. First, you must show that the job by its nature calls for a directly related degree. Only then do you show that your candidate has that degree (or a closely related one). The 2025 rule explicitly avoided any wording that would mistakenly shift the focus to the individual’s exact degree title. Instead, it aligns with the idea that what matters is the link between the job’s duties and the type of degree required for that job. In short: define the job’s qualifications based on the job’s needs, not the individual’s background.

“Directly Related” in Practice: Employers Must Show a Logical Connection

The January 2025 H-1B final rule did not invent the phrase “directly related.” That language has existed for years in the F-1 student context. Both curricular practical training and optional practical training require that the training opportunity be directly related to the student’s major area of study. Many F-1 students have already practiced explaining this relationship when requesting OPT in the SEVP portal, and STEM OPT applicants do something similar in Form I-983 for review by the Designated School Official. In 2019, DHS issued SEVP policy guidance to help schools evaluate whether a student’s job is directly related to the major, and that guidance used a “logical connection” approach to describe the required relationship. That same “logical connection” concept later appeared in the H-1B final rule, but in the H-1B setting, the focus is different: the petitioner must establish a logical connection between the position’s duties and the specific field of study the position requires as its minimum entry requirement, not a post hoc match based on a particular worker’s background.

Neither the H-1B specialty occupation regulations nor the F-1 practical training (OPT) regulations explicitly define how to establish a “logical connection” between a degree and job duties. However, guidance from the Student and Exchange Visitor Program (SEVP) provides insight through sample explanations for students to demonstrate this direct relationship. For example, SEVP’s policy guidance on OPT offers model statements like:

• Bachelor’s degree in Business: “I work full-time as a Loan Officer at a mortgage company, Happy Homes, where I meet with clients and evaluate, authorize, and recommend approval of loan applications. On a daily basis, I use the knowledge I gained in my credit analysis, sales, and marketing classes that I took as part of my major program of study.”
  
• Ph.D. in Computer Science: “I am employed as a Computer and Information Research Scientist at ABC Research Institute. I work as part of a team of scientists and engineers that designs experiments to test the operation of various software systems. My work builds on research in complex algorithms and machine learning, which I studied as part of my dissertation.”
  

These examples follow a simple logic: the individual outlines their main job tasks and then directly ties those tasks to knowledge gained from specific courses or research in their degree program. In other words, the explanation highlights how the day-to-day duties draw upon the academic training from that field of study. This framework, describing what the job entails and how the degree’s coursework relates, can be very useful when writing a direct relationship explanation. Employers can adopt a similar approach in H-1B petitions by detailing the position’s responsibilities and linking each duty to particular skills or concepts taught in the required degree program.

For additional evidentiary support, employers might leverage resources that SEVP recommends for connecting jobs to academic programs. Examples include O*NET (the Department of Labor’s occupational database), the College Board’s career guidance for college majors, and the National Center for Education Statistics’ CIP code database. These tools provide a “job–program crosswalk,” helping to show that a given role is associated with a certain field of study.

That said, despite using the same “direct relationship” terminology, the H-1B specialty occupation context is more restrictive than the OPT context. To illustrate the difference:

• OPT practical training context: A student only needs to demonstrate that their job duties have a direct relationship to their major field of study. If the role’s tasks logically connect to what the student learned in their degree program, it can qualify as appropriate practical training.
  
• H-1B specialty occupation context: The employer must demonstrate not only that the duties relate to a field of study, but that the job requires a specific degree in that field. In other words, the position should demand highly specialized knowledge such that someone with a general degree (or an unrelated background) could not perform it. If a role can be done by an individual with a broad or general education, it will not meet the H-1B specialty occupation standard.
  

In practical terms, an H-1B petition needs to show why the degree matters for the work. Using the business degree example above: it’s not enough to say the candidate uses skills from credit analysis or marketing classes. The employer should explain that those skills are specific to a business degree (or a narrow range of related degrees) and are indispensable for the role. Therefore, it is wise for the H-1B employer to provide a detailed description of the position’s duties and clearly explain how each duty requires knowledge obtained through a particular bachelor’s-level field of study (or a defined set of fields). By explicitly mapping job duties to specialized coursework, the petition highlights that the job calls for “highly specialized knowledge” imparted by that degree. This level of detail aligns with USCIS’s expectations under the specialty occupation definition. For example, recent guidelines emphasize clearly defining the role’s specialized skills and ensuring the degree requirement is directly related to the job’s responsibilities. Such thorough documentation makes a stronger case that the position is a true specialty occupation and not one attainable with general education.

Why This Matters and How Cho Law LLC Can Help

The “directly related” degree requirement isn’t actually a brand new concept – it’s a clarification of what Congress always intended for H-1B specialty occupations. By codifying it in the regulations, USCIS is signaling that it will scrutinize petitions to ensure the job’s degree requirement is legitimate and appropriate. This means employers filing H-1B petitions need to be extra diligent in how they craft job descriptions and minimum qualifications. If the connection between the degree and the job is weak or not well explained, you risk Requests for Evidence (RFEs) or denials. On the flip side, if you clearly demonstrate that your position requires a specific, specialized degree and you back it up with reasoning and evidence, you stand a much better chance of approval – and you help avoid delays in the process.

At Cho Law LLC, we routinely help employers navigate these kinds of issues. We can assist in reviewing your H-1B job requirements, helping you articulate why a certain degree is needed, and identifying supporting evidence (like O*NET data or academic program info) to strengthen your case. The new rule puts the onus on you as the petitioner to show the direct relationship, but you don’t have to figure it out alone. Our team stays up-to-date with the latest regulations (like this January 2025 update) and can guide you in preparing solid H-1B petitions under the new standards.

If you have questions about how the H-1B modernization rule affects your hiring or need help with a case, contact Cho Law LLC – we’re here to help ensure you get it right.

Disclaimer: This article provides general information and should not be construed as legal advice. For guidance tailored to your specific circumstances, please consult with a qualified immigration attorney.