On June 13, 2025, U.S. Citizenship and Immigration Services issued policy guidance in the USCIS Policy Manual to enhance the integrity of the review process for Form N-648, Medical Certification for Disability Exceptions.

 Across the country and over the decades, there have been numerous instances where the medical certification process has been exploited. When a medical professional provides a false certification, it not only undermines the purpose of the disability exception but also weakens the credibility of the entire naturalization system, because it causes USCIS to naturalize aliens who have not established eligibility for naturalization.   

Background
In 1994, Congress enacted legislation providing an exception to the English and civics requirements for aliens applying to naturalize who cannot meet the requirements because of a medically determinable physical or developmental disability, or mental impairment. The Department of Homeland Security implemented these provisions at 8 CFR part 312 and designated Form N-648 as the form to request an exception to the English and civics requirements. Form N-648 must be completed and certified by a medical professional who attests that the alien’s medical condition, that has lasted, or is expected to last, at least 12 months, prevents them from meeting the English or civics requirements, or both. 

What You Need to Know
This policy update: 

• Implements changes to processing medical certifications to enhance the integrity of the process and to allow for additional review and identification of fraud;
  
• Returns to the prior policy (pre-2022) of requiring aliens filing for naturalization to submit Form N-648 concurrently with the Application for Naturalization (Form N-400), except when the alien demonstrates extenuating circumstances;  

• Provides that concurrent submission of multiple Forms N-648 may raise concerns about the credibility of the disability or impairment claim and could be subject to further review;  

• Reaffirms that the medical professional must clearly explain the connection (also referred to as the nexus) between the disability or impairment and how it renders an alien unable to demonstrate the English and civics requirements for naturalization; and  

• Explains the policy regarding credible reasons to doubt the validity of Form N-648, by introducing examples of credible reasons and how USCIS handles these situations. 

More Information
For more information, visit our Medical Certification for Disability Exceptions page.

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