US Citizenship and Immigration Services (USCIS) has implemented new policy guidance that increases scrutiny of Form N-648, Medical Certification for Disability Exceptions, used by naturalization applicants seeking a waiver from the English and civics testing requirements. The changes, effective immediately, are intended to improve the integrity of the review process and prevent fraud.
Under US immigration law, applicants for naturalization must typically demonstrate proficiency in the English language and a knowledge of US history and civics. An exception exists for individuals who, due to a physical or developmental disability or mental impairment, are unable to meet these requirements. To qualify, applicants must submit Form N-648, certified by a licensed medical professional.
The new guidance, detailed in Volume 12 of the USCIS Policy Manual, places a greater emphasis on the connection between the diagnosed condition and the applicant’s inability to learn. According to the updated policy, it is no longer sufficient for a medical professional to simply state that an applicant has a disability. The certifying medical professional must now provide a detailed explanation of how the applicant’s condition and its symptoms directly prevent them from meeting the educational requirements for naturalization.
USCIS has also indicated that the submission of multiple N-648 forms for a single applicant may be a red flag, potentially triggering a more thorough review of the case. The agency has stated that this measure is being implemented to address concerns about the credibility of some disability claims.
The policy change is being enacted to address what USCIS has described as past exploitation of the medical certification process. The agency maintains that false certifications undermine the naturalization system by allowing individuals who have not met the statutory requirements to obtain citizenship.
This new guidance is issued in support of Executive Order 14148, “Initial Rescissions of Harmful Executive Orders and Actions,” and Executive Order 14159, “Protecting the American People Against Invasion.” The updated policy applies to all naturalization applications and associated Forms N-648 filed on or after June 13, 2025.
Person with disability. Photo credit: makeitsomarketing from Pixabay.
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