How can value-add real estate syndications qualify for EB-5 capital?

I am a real estate syndicator that focuses on value-add apartment complexes. We have a need for private capital for the equity side of the investment and are looking into different options. These projects come up quickly and are typically closed within +-90 days which might be too short of a timeline to meet all the EB-5 requirements, but thought it was worth asking. Most syndications do not directly hire people for jobs, but there is job creation through increased property management personnel and via the upgrades happening at the property that would create jobs for contractors, landscapers, maintenance personnel, etc. To qualify for an EB-5 investment, does our company need to directly employ the workers, or can we just provide proof of creating jobs via our projects if that would meet the requirements?