No. Adding separate part-time positions is not automatically equivalent to qualifying full-time employment.
Assess the actual positions
Direct full-time positions generally require at least 35 weekly hours. Genuine job sharing is a different arrangement and needs relevant evidence; the actual framework matters.
The reduced amount is not a discount that can be claimed by describing a location as rural; it depends on the project actually falling within a targeted employment area or qualifying infrastructure category as those are currently defined. A direct EB-5 investment in a new commercial enterprise the investor owns and manages is permitted, provided the applicable capital is at risk, ten full-time direct jobs for qualifying workers are created, the funds are lawfully sourced and the investor engages in management. The investment structure, the lawful source and path of the capital, the applicable at-risk requirement, and the qualifying job-creation evidence all need to be independently established, in addition to investing the correct amount for the specific project type. An investment not associated with a regional center must create at least ten full-time jobs for qualifying U.S. workers directly, without relying on indirect or induced employment calculated through economic models.