On June 13, 2025, the U.S. Citizenship and Immigration Services (USCIS) released revised policy guidance for the submission and adjudication of Form N-648, Medical Certification for Disability Exceptions, used by naturalization applicants seeking exemption from the English and civics test due to qualifying disabilities. These changes mark a return to stricter standards and increased scrutiny, aiming to enhance the integrity of the naturalization process and prevent fraud.
What Is Form N-648?
Form N-648 is used by applicants who are medically unable to meet the English and civics testing requirements for naturalization under INA § 312(b). The form must be completed by a licensed medical doctor, doctor of osteopathy, or clinical psychologist in the United States. The medical condition must be determined to last at least 12 months and must render the applicant unable to learn or demonstrate the required knowledge of U.S. history, government, or English.
Key Policy Updates as of June 2025
The new policy guidance reinstates several pre-2022 requirements and introduces new mechanisms to identify potential fraud, as outlined in the USCIS Policy Manual Volume 12, Part E. The most significant changes include:
1. Mandatory Concurrent Filing
Applicants must now submit Form N-648 at the same time as Form N-400, unless they can prove extenuating circumstances. Late filings will be more closely scrutinized and must be justified.
2. Heightened Review for Multiple Submissions
Submitting multiple Forms N-648 for a single applicant may raise red flags and prompt additional investigation. USCIS may consider this a credibility issue.
3. Stronger Emphasis on Medical Nexus
Medical professionals must clearly and thoroughly explain how the applicant’s disability directly prevents them from fulfilling the English and civics requirements. Vague or incomplete explanations may result in rejection or requests for supplemental evidence.
4. Identification and Handling of Fraud
New examples of credible reasons to doubt the validity of a Form N-648 are now included. USCIS officers are instructed on when to request additional certifications from different medical professionals or deny the exemption altogether.
5. Interpreter and Examination Protocols
Updates clarify that the presence of an interpreter during the medical examination must be documented and that the interpreter must not influence the assessment. Telehealth protocols are addressed separately.
Why This Matters
Over the years, federal investigations have uncovered multiple fraud schemes involving medical professionals submitting false disability claims. For example, one doctor was found guilty of fraudulently completing over 1,200 N-648s, while another submitted 3,000+ false certifications over a 14-year period. These abuses have led USCIS to take a firmer stance on ensuring that only those genuinely medically exempt from testing requirements benefit from the waiver.
What This Means for Applicants
If you are considering filing Form N-648, it’s critical to:
- Work with a licensed and experienced medical provider
- Ensure the form is complete, detailed, and accurate
- File concurrently with Form N-400
- Be prepared to explain any late or supplemental submissions
USCIS now treats these disability waivers with heightened skepticism, and any inconsistencies or insufficient documentation can delay or derail your naturalization process.
Need Help?
At Ahluwalia Law Offices, we guide applicants and their families through the naturalization process with care and precision, including assistance with N-648 submissions. If you or a loved one is applying for U.S. citizenship and needs a disability exception, consult with us to ensure your application meets the latest USCIS standards.
