EB5 Healthcare Investment
EB-5 healthcare investment qualifies through operational job creation, not just construction. Clinical staff, administrative personnel, and support roles all count toward the 10-job-per-investor requirement every EB-5 petition must satisfy. A functioning healthcare facility creates those positions through its ongoing operations.
Polaris EB-5 Regional Centers has one active healthcare project: the Sacramento PACE Center, a Program of All-Inclusive Care for the Elderly serving older adults in California. The founders carry operational backgrounds in pharmacy, electronic health records, pharmacy automation, and medical staffing.
How It Works
Under the regional center model, investors contribute capital to a New Commercial Enterprise (NCE). The NCE deploys that capital into the healthcare facility, the Job-Creating Entity (JCE). The JCE operates the program and employs the staff whose jobs count toward USCIS requirements.
Investors do not manage or operate the facility. Their role is to provide qualifying capital and document the lawful source and path of those funds.
Job creation is measured using a USCIS-accepted economic model such as RIMS II or IMPLAN. These models project three job categories:
- Direct jobs (staff employed by the facility)
- Indirect jobs (suppliers and vendors)
- Induced jobs (local-economy spending by those employees)
USCIS accepts all three categories for regional center petitions. Job figures are projections. USCIS verifies actual job creation when the investor files the I-829 petition to remove conditions.
The minimum investment is $800,000 for projects in a USCIS-designated Targeted Employment Area (TEA) and $1,050,000 for all other projects. These amounts are set by statute under the EB-5 Reform and Integrity Act of 2022 (8 U.S.C. § 1153(b)(5)).
For a full explanation of the regional center model and petition sequence, see the EB-5 Regional Centers page and the EB-5 Program page.
Why Healthcare Suits EB-5
Healthcare facilities are labor-intensive by design. The ratio of staff to patients is set by care standards and, in some cases, federal program rules. That staffing reality produces job numbers that hold up under USCIS scrutiny.
Non-discretionary demand.
People need medical care regardless of broader economic conditions. An adult day health program does not see demand contract the way a hotel might in a downturn. That stability supports the multi-year investment horizon EB-5 petitions require.
An aging U.S. population.
The U.S. Census Bureau projects that adults 65 and older will make up roughly 22% of the U.S. population by 2040. Adult day health programs and PACE centers address a growing, not contracting, need.
Federal program recognition.
PACE operates within a federally recognized framework under the oversight of CMS (Centers for Medicare & Medicaid Services). That regulatory structure adds documentation discipline to project operations, which is relevant to USCIS's evaluation of a project's business plan.
None of these factors determines the outcome of your investment or petition. Your capital is at risk, as it is in any EB-5 investment. Job figures are projections.
What Polaris Looks For
Polaris evaluates healthcare projects against several criteria before including them in its regional center network. The same criteria shape how a project is documented for USCIS.
| Criterion | What Polaris Reviews |
|---|---|
| Operational history | Facilities with an operating track record provide real employment data, not just projections. Real data strengthens the economic methodology underlying the petition. |
| TEA eligibility | If the project site is in a USCIS-designated TEA, the investment minimum is $800,000 rather than $1,050,000. Polaris confirms TEA status for each project before accepting investor capital. Investors should review the offering documents. |
| NCE / JCE structure | The separation between the New Commercial Enterprise and the Job-Creating Entity must be properly documented. Polaris works with securities and immigration counsel to establish this structure for each project. |
| Disclosure quality | Healthcare projects involve state licensing, CMS certification, and HIPAA obligations. Polaris requires those disclosures to be complete before a project is offered to investors. |
| Operator credibility | Polaris founders have direct operational backgrounds in pharmacy, electronic health records, pharmacy automation, and medical staffing. That background informs how operators are evaluated. |
For an overview of all sectors Polaris covers, see the EB5 Investment Options page. For other sectors, see EB5 Real Estate Investment and EB5 Technology Investment.
Risks to Understand
Your capital is at risk, as it is in any EB-5 investment. The risks below apply specifically to healthcare projects and should be read alongside the full offering documents for any project you consider.
Petition risk.
USCIS reviews each petition independently. Approval of your I-526E does not automatically mean approval of your I-829. Job-creation requirements must be verified at the I-829 stage.
Project risk.
Healthcare project timelines can be affected by licensing delays, staffing challenges, or changes in care delivery models. The offering documents disclose these risks.
Regulatory risk.
Healthcare facilities operate under state and federal oversight. A change in licensure, CMS certification status, or reimbursement rates could affect facility operations and the jobs underlying your petition.
Capital risk.
Investor capital is placed into escrow before release to the project. Escrow governs the timing of capital release, not the outcome of your investment or petition. Your principal may not be returned.
Immigration risk.
The EB-5 program offers a path to U.S. permanent residency. Each stage of the petition process involves an independent USCIS review. Consult qualified immigration counsel about your specific situation.
Review the full offering documents and consult qualified immigration and securities counsel before committing capital.
Talk to a Specialist
A Polaris specialist can walk you through the Sacramento PACE Center project structure, the offering documents, and the petition process as it applies to your situation.
Frequently Asked Questions
Any licensed healthcare facility that creates at least 10 qualifying full-time jobs per investor position can serve as a job-creating entity. Under the regional center model, this includes direct, indirect, and induced jobs as calculated by a USCIS-accepted economic model. Qualifying types include adult day health programs, skilled nursing facilities, assisted living facilities, and outpatient clinics. The specific project structure and economic methodology matter more than the facility type alone.
TEA status for the Sacramento PACE Center is determined by USCIS based on census tract data and is disclosed in the project's offering documents. Polaris confirms TEA status before accepting investor capital. Contact a Polaris specialist for current project details.
A healthcare facility creates jobs through ongoing operations: clinical staff, administrative personnel, and support roles. Under the regional center model, indirect and induced jobs projected by a USCIS-accepted economic model supplement those direct positions. All job figures are projections. USCIS verifies actual job creation at the I-829 stage.
Your capital is at risk in any EB-5 investment. Operational or financial difficulties at the job-creating entity can affect both the return of your capital and the job-creation figures underlying your I-829 petition. Escrow governs when capital is released to the project, not what happens to it afterward. Review the offering documents with qualified securities and immigration counsel before investing.
Your current visa status does not prevent you from making an EB-5 investment. H-1B holders in the U.S. may file an I-526E petition while maintaining their H-1B status. After petition approval, you may be able to adjust status in the U.S. rather than applying for a visa abroad, depending on your circumstances. Consult a qualified immigration attorney about how your specific situation affects your options.
For a full overview of EB-5 investment options across all pathways and sectors, visit the EB5 Investment Options page.