The proposed PERM regulations would codify current INS practices by preventing nurses without either CGFNS or a "full and unrestricted license" from having a permanent visa petition approved on their behalf. The problem with this formulation is that in order to obtain a license, a nurse usually must be in possession of a
social security number. This is next to impossible for a nurse who resides abroad or who is present in the United States as a visitor or a student. Without a social security number, it is impossible for most nurses to obtain a state license. This forces nurses, even those who have passed the NCLEX examination, to take and pass the CGFNS examination as well even if this is not required to obtain a state license.
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