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2.0

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

  1. Original Date Announced

    August 29, 2025

    USCIS issued a notice and request for comments on proposed changes to Form N-648, Medical Certification for Disability Exceptions. USCIS uses 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).

    The proposed changes increase the questions in the form about the applicant's disabilities and impairments and add more stringent qualification standards, including a requirement for in-person exams. The changes also seek to disqualify applicants whose disability or impairment has not lasted 12 months, or whose disabilities and impairments were a direct result of the use of illegal drugs. The proposed changes further require information about the doctor's prescribed treatment and the applicant's daily activities, such as whether the disability or impairment prevents the applicant from obtaining employment.

    Comments are due on October 28, 2025.

    Trump 2.0 [ID #1992]

    2025.07.22 USCIS Table of Changes Form N-648, Medical Certification for Disability Exceptions 2025.07.22 USCIS Table of Changes Instructions for Form N-648, Medical Certification for Disability Exceptions 2025.08.29 DHS 60-Day Notice of Agency Information Collection; Revision of Disability Exceptions 2025.08.29 USCIS Form N-648 Instructions for Medical Certification for Disability Exceptions 2025.08.29 USCIS Form N-648 Medical Certification for Disability Exceptions

Current Status

None

Original Trump Policy Status

Status: Proposed Comment Period
Trump Administration Action: Forms and Information Collection
Subject Matter: Naturalization
Agencies Affected: USCIS

Associated or Derivative Policies

Commentary

  • 2025.10.01 ILRC - Comment Opposing Proposed Changes

    The Immigrant Legal Resource Center (ILRC) submitted a comment opposing the proposed revisions, arguing that the changes violate existing statutes, regulations, and USCIS's Policy Manual. The ILRC asserts that the length of the additions, which would more than double the current version of the form, creates an undue burden on applicants, medical professionals, and adjudicators. The ILRC also contends the new provisions invent unauthorized standards, specifically arguing that the requirement for in-person exams conflicts with USCIS's previous practice of allowing telehealth examinations. The ILRC also argues that the revisions add unnecessary and inappropriate oath waiver questions that medical professionals are unqualified to answer, and appear based on an unsupported assumption of fraud.

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Documents

Trump-Era Policy Documents

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