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Original Date Announced
April 26, 2019USCIS 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 OMBEffective Date
July 23, 2020Subsequent Trump-Era and Court Action(s)
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September 6, 2019
30 day notice and request for comments
USCIS notifies the public that it will be submitting the following information collection request to the OMB for review and clearance and allows an additional 30 days for public comments.
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July 23, 2020
OMB approves information collect request
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July 23, 2020
New Form N-648 (7/23/20 edition)
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July 23, 2020
New Form N-648 Instructions (7/23/20 edition)
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Biden Administration Action: Revoked/Replaced
August 19, 2022Instructions 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 DocumentBiden Administration Action: Revoked/Replaced
August 19, 2022Form 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.
Biden Administration Action: Revoked/Replaced
October 19, 20222022.10.19 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 DocumentCurrent Status
Not in effectMost Recent Action
October 19, 2022 Action: Revoked/Replaced 2022.10.19 USCIS Form and Policy Updates Remove Barriers to Naturalization for Applicants with DisabilitiesAugust 19, 2022Acted on by Biden Administration
August 19, 2022Acted on by Biden Administration
October 19, 2022Acted on by Biden Administration
Original Trump Policy Status
Status: Final/Actual RescindedTrump Administration Action: Forms and Information CollectionSubject Matter: NaturalizationAgencies Affected: USCISAssociated or Derivative Policies
Pre Trump-Era Policies
- May 23, 2019 05/23/2019 edition of N-648
- May 23, 2019 05/23/2019 edition of N-648 Instructions
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 articleCLINIC comment to proposed form changes
CLINIC submits comments on proposed revisions to N-648.
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