An EB-1A RFE can question both sustained acclaim and whether the person is among the small percentage at the very top of the field. That can make the final-merits section feel like two separate essays. It does not have to be.
The headings are an editing choice, not a required USCIS format. If the notice treats the two points separately, two short subsections can help the officer find each answer. The final paragraph should still explain what the whole record shows when the evidence is weighed together.
A workable outline:
1. Sustained acclaim. Put the recognition on a timeline. Identify who recognized the work, when, and where the independent record shows that the recognition continued. Do not call routine career progression “sustained” without showing the underlying evidence.
2. Top-of-field standing. Name a relevant peer group and explain why the strongest evidence distinguishes this person within it. A big number, title, or well-known employer needs context. What makes the comparison credible?
3. Whole-record synthesis. Connect the strongest independent signals. An exhibit may support both points; cite it once clearly rather than copying the same story into two sections. Explain how the evidence works together and address the specific gap the officer raised.
Before editing headings, read the RFE's actual language. If it challenges a missing source or weak comparator, structure alone will not solve the problem. Put that unresolved question in front of qualified counsel.
I added a more detailed outline to the free ChatEB1 guide: https://chateb1.com/blog/how-to-structure-your-eb1a-final-merits-section
Source: USCIS Policy Manual, Volume 6, Part F, Chapter 2. This is educational material for organizing a record, not legal advice.
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