It depends on the actual change and the basis of the existing authorization. A promotion label alone does not answer whether the work remains within the approved professional arrangement. Compare the proposed responsibilities with the original duties and have counsel assess the difference.
Review substance and timing together
Provide the new job description, organizational context, and planned effective date. If the role becomes materially different, the reviewer needs to consider profession fit and the appropriate action before the work changes. Do not simply reuse the prior employer letter with a new title.
The applicant’s qualifications may be unchanged while the new position raises a different eligibility question, making a fresh factual comparison essential. Promotion language also hides a scope question the reviewer has to answer directly: does the new position still sit inside a profession named in the USMCA appendix, and does the worker hold the qualification that occupation requires? Moving from a listed professional role into general management, supervision or business development is the common way people leave the category without noticing, because the pay rises and the employer never changes.
Hypothetical example: a college teacher promoted to lead a curriculum department may still teach, or may have become an administrator whose teaching is incidental, and only a duty breakdown separates the two. Request the proportion of time attached to each responsibility rather than relying on the organisational chart.