US Citizenship and Immigration Services (USCIS) is issuing policy guidance to enhance the integrity of the review process for Form N-648, Medical Certification for Disability Exceptions.
Under this guidance, USCIS is changing how it processes Form N-648 by focusing greater attention on the veracity of medical certifications and identification and prevention of fraud, thereby enhancing the integrity of the process.
Generally, aliens applying for naturalization must demonstrate understanding of the English language and knowledge and understanding of the civics fundamentals of the history and principles and form of government of the United States. Aliens applying for naturalization who are seeking an exception to the English and/or civics requirements because of a medically determinable physical or developmental disability or mental impairment that has lasted, or is expected to last, at least 12 months, must submit Form N-648 attesting to the medical condition, which must be completed and certified by a medical professional.
The guidance confirms that the medical professional completing Form N-648 must explain how the disability or impairment leaves the alien unable to meet the English and civics requirement for naturalization (the presence of a disability alone is not sufficient).
This guidance also provides that submitting multiple Forms N-648 concurrently may raise concerns about the credibility of the disability or impairment claim and could be subject to further review.
This guidance, contained in Volume 12 of the USCIS Policy Manual, supports Executive Orders 14148 Initial Rescissions of Harmful Executive Orders and Actions and 14159 Protecting the American People Against Invasion. It is effective immediately, and applies to all naturalization applications and associated Forms N-648 filed on or after June 13, 2025.
Erickson Insights & Analysis
Erickson Immigration Group will continue to monitor developments and share updates as more news is available. Please contact your employer or EIG attorney if you have questions about anything we’re reporting above or case-specific questions.