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USCIS proposes revisions to N-648, Medical Certification for Disability Exceptions

  1. Original Date Announced

    April 26, 2019

    USCIS requests comments on proposed changes to Form N-648, Medical Certification for Disability Exceptions. USCIS uses the Form N-648 to substantiate a claim for an exception to the requirements of section 312(a) of the INA. By certifying Form N-648, the doctor states that an applicant filing an Application for Naturalization, Form N–400, is unable to complete the English and/or civics requirements because of a physical or developmental disability or mental impairment(s).

    Among the proposed changes to the form and instructions include expanding the list of questions on the disability and impairment from 12 questions to 23 questions. The new form has added new questions regarding the date that each disability/impairment began; the date of diagnosis; the severity of each disability/impairment; how each disability/impairment affects the applicant’s daily life activities; why each disability/impairment is expected to last over 12 months; which disability/impairments are the result of illegal drug use; the frequency of treatment; and if the medical professional questioned the interpreter about his/her fluency in English and accuracy/completeness in interpretation.

    [ID #1239]

    60 Day Notice and Request for Comments N-648 Table of Changes to Instructions Table of Changes Form Supporting Statement Submitted to OMB
  2. Effective Date

    July 23, 2020
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  4. Biden Administration Action: Revoked/Replaced

    August 19, 2022

    Instructions to Form N-648, 8/19/22 edition

    This Biden administration policy reverses the Trump era policy identified in this entry.

    On 8/19/22, the Biden administration released a revised edition of Form N-648 and instructions.

    View Document
  5. Biden Administration Action: Revoked/Replaced

    August 19, 2022

    Form N-648, 8/19/22 edition

    This Biden administration policy reverses the Trump era policy identified in this entry.

    On 8/19/22, the Biden administration released a revised edition of Form N-648. Among the key changes to the form include:

    • The new edition of Form N-648 has been shortened to just over 4 pages, in comparison to 9 pages from the previous edition.
    • The number of questions in Part 3, Information About Disabilities and/or Impairments, has been trimmed down and simplified.
    • In Part 3, prior questions about the clinical diagnosis and the connection between the disability/impairment and inability to meet the testing requirements have been combined in the first question.
    • A new section has been added in Part 4, Ability to Understand Oath of Allegiance. In this section, the medical professional is asked if the applicant is able to understand and communicate an understanding of the oath.
    View Document
  6. Biden Administration Action: Revoked/Replaced

    October 19, 2022

    2022.10.19 USCIS Form and Policy Updates Remove Barriers to Naturalization for Applicants with Disabilities

    This Biden administration policy reverses the Trump era policy identified in this entry.

    USCIS announced updated policy guidance to clarify and conform with the revision of Form N-648, Medical Certification for Disability Exceptions. Notable changes include the elimination of questions about how each relevant disability affects specific functions of the applicant’s daily life, including the ability to work or go to school, dates of diagnosis, description of severity of each disability, and whether the certifying medical professional has a pre-existing relationship with the applicant. Further, the form revision allows the medical professional the option to indicate an applicant’s need for an oath waiver, thereby eliminating the need for separate medical documentation.

    View Document

Current Status

Not in effect

Most Recent Action

October 19, 2022 Action: Revoked/Replaced 2022.10.19 USCIS Form and Policy Updates Remove Barriers to Naturalization for Applicants with Disabilities
August 19, 2022
Acted on by Biden Administration
August 19, 2022
Acted on by Biden Administration
October 19, 2022
Acted on by Biden Administration

Original Trump Policy Status

Trump Administration Action: Forms and Information Collection
Subject Matter: Naturalization
Agencies Affected: USCIS

Pre Trump-Era Policies

Commentary

  • ILRC Practice Alert on Form N-648 changes

    The ILRC provides a practice alert which describes recent changes to the naturalization disability waiver.

    Go to article
  • CLINIC comment to proposed form changes

    CLINIC submits comments on proposed revisions to N-648.

    Go to article

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