Yes, as a standalone investor, if she invests the qualifying amount at risk in a new commercial enterprise she manages and the clinic creates at least ten full-time direct jobs for qualifying U.S. workers, with source and path of funds documented. Without a regional center, indirect jobs do not count.
What the standalone route demands
The standalone route removes the regional center's project file and puts everything on her own plan. Three elements carry the weight. First, the capital: the full qualifying amount, at the threshold that applies to the clinic's location, must be placed at risk in the enterprise, spent or committed to the clinic's build-out, equipment and operations rather than held in reserve.
Second, the jobs: ten full-time positions on the clinic's payroll, for U.S. citizens, permanent residents or other authorized workers, created within the period the rules allow; an economic model counting suppliers' or landlords' jobs is not available to a standalone investor. Third, the funds: a lawful source and an unbroken path from the practice sale to the clinic.
Her role as owner-manager satisfies the engagement requirement. Confirm the current capital thresholds and targeted-employment-area rules on the USCIS site at filing, since they are subject to adjustment, and treat the two-year conditional period as a stage, not the finish.