No. The official corporate description is for sponsored employees. Establish the actual relationship and proposed arrangement rather than inferring employee eligibility from the payment offer.
Assess the relationship behind the commercial label
A consulting agreement or invoice is not the whole analysis. Do not simply rename the service provider or invent an employment history to fit the proposal; document the real facts and applicable process.
Each proposed principal remains subject to the appropriate eligibility, admissibility and visa-availability requirements. The official FAQ describes the gift after successful vetting and bank instructions. Treat the medical payment as completion of one instructed step, never as an eligibility finding. The decision record is the official program instruction together with the applicant’s eligibility and source documents. Successful applicants proceed under existing EB-1 or EB-2 classifications with their own eligibility and visa availability rules. The gift is a gift payment, not EB-5 capital or a stand-alone visa purchase, and current official instructions should be rechecked before any transfer.
An approved recruiting or hiring budget is an internal corporate decision, not a step in the government's Gold Card sequence. Begin with the official description and identify what, if anything, it presently authorizes.