New Filing Requirements for Medical Certification in Naturalization Process
USCIS guidelines for Form N-648: who qualifies and how to avoid mistakes
Form N-648 lets certain naturalization applicants request exceptions to the English and/or civics tests due to a medically determinable physical or developmental disability or mental impairment. However, approvals depend on clear medical evidence, correct completion by an eligible professional, and consistency with your N-400.
Core eligibility (what USCIS looks for)
The condition is medically determinable (diagnosed by licensed medical professional).
The impairment has lasted or is expected to last at least 12 months.
Because of the impairment, the applicant cannot meet the English and/or civics requirements even with reasonable accommodations.
Therefore, the form must explain why study, instruction, or interpreters won’t overcome the limitations.
Who can complete the N-648
Licensed medical doctors (MD/DO)
Clinical psychologists (PhD/PsyD)
Certain qualified medical professionals permitted by USCIS policy
They must examine the applicant, sign/date the form, and include license information and practice details.
How to complete a strong N-648 (section by section)
Diagnosis & history: Provide specific diagnoses, onset dates, course of treatment, and relevant testing (e.g., neuropsych, imaging).
Functional impact: Describe how the impairment limits learning, memory, attention, language, or mobility. Use concrete examples.
Why accommodations aren’t enough: Explain why interpreters, extra time, or simplified materials still won’t work.
Certify duration: Clarify that the impairment meets the 12-month rule (past or expected).
Interpreter/preparer details: If used, list names and certifications consistently.
As a result, the officer sees medical facts, not just conclusions.
Common pitfalls (and how to avoid RFEs/denials)
Vague diagnoses (“memory problems”) → Use DSM/ICD labels and testing references.
Copy-paste letters without patient specifics → Include individualized daily-function examples.
Mismatch with N-400 (e.g., employment/schooling claims) → Align all forms and explanations.
No link between condition and testing → Spell out why English/civics cannot be learned or recalled.
Missing signatures/dates → Check every signature, date, and license field before filing.
Reasonable accommodations vs. N-648
Applicants may request accommodations (e.g., interpreter for sign language, extra time). However, the N-648 is different—it asks USCIS to waive the English/civics tests because the impairment prevents learning/testing even with accommodations.
Filing tips (step-by-step)
Screen first: Confirm eligibility and risks (travel, arrests, taxes).
Schedule evaluation: Bring ID, medical history, medication list, and prior testing.
Draft carefully: Ensure dates and facts match the N-400 and any court/medical records.
Upload with N-400 (or bring to interview): Follow current USCIS instructions.
Prepare the applicant: Even with a waiver, be ready to answer biographic questions and discuss the condition in simple terms.
If USCIS asks for more (RFE/NOID)
Provide updated records, detailed provider letter, and any new testing.
Address each officer concern point-by-point, and therefore correct any inconsistencies across forms.
Evidence checklist (bring to your consult)
Government ID and green card
Prior medical records, evaluations, imaging, therapy notes
Medication list and side-effect impacts
School/IEP or disability records (if any)
Names/contact info for treating providers and potential evaluators
FAQs
Do I still attend the interview?
Yes. However, the English/civics tests may be waived if the N-648 is approved.
Can my family doctor sign it?
If they’re a licensed MD/DO (or qualified clinician under policy) and they examine you, yes—so long as they supply specifics.
What if my condition improves later?
The N-648 must reflect the condition at filing/interview and meet the 12-month standard.
Is dementia the only qualifying condition?
No. Instead, many conditions (e.g., stroke, TBI, developmental disabilities, severe psychiatric disorders) can qualify if they prevent learning/testing.
How we help
First, we screen eligibility and collect records. Next, we coordinate a thorough evaluation with a qualified clinician and ensure the N-648 is complete and consistent. Then, we file it with your N-400 and prep you for interview. Finally, we handle RFEs/NOIDs and any accommodation needs.
Need help with an N-648 for naturalization? Schedule a consultation or call (562) 495-0554.
Disclaimer: General information, not legal advice. USCIS policies and form editions change; we confirm the instructions in effect when we file.
United States Citizenship and Immigration Services
Applicants must now submit the form at the same time as their N-400 application. USCIS will also increase its review and scrutiny of these forms. This is one of many recent updates to the USCIS policy manual. Over the past two weeks, USCIS has released six policy alerts and two technical updates.
The new guidelines place a strong emphasis on concurrent filing.
Applicants are now required to submit Form N-648 as an attachment to their Form N-400, Application for Naturalization. This reverts to a policy that was in place before 2022.
- Late Submissions: USCIS may still accept a Form N-648 filed after the N-400, but only if the applicant can demonstrate extenuating circumstances.
For example, a late submission might be accepted if the disability or impairment developed or worsened after the N-400 was filed. The applicant must provide a clear written or verbal explanation for the delay. - Multiple Submissions: Submitting multiple N-648 forms at the same time or a new form after one has already been filed will be closely scrutinized. USCIS sees this as a potential red flag that could raise concerns about the credibility of the disability claim.
