Several years ago, the U.S. Citizenship and Immigration Services (USCIS) announced the release of revised Form N-648, Medical Certification for Disability Exceptions, for those seeking an exception from the English and civics requirements for naturalization because of disabilities. Immigration law requires that individuals applying for Naturalization/Citizenship must exhibit proficiency of U.S. civics and the English language. Individuals, who have disabilities or impairments, may seek exceptions from either or both of these requirements. Applicants, who ask for such an exception, must file Form N-648.
Form N-648 was revised following input from USCIS subject-matter experts, customers, medical professionals, community-based organizations and immigration lawyers. The intentions of these revisions were to clarify the requirements and instructions as well as to standardize the process for applicants, medical professionals and USCIS officers. The Form allows medical professionals to provide information that is necessary for USCIS so that immigration officials can better understand the medical professional’s diagnosis and how it relates to the naturalization requirements.
- The requirements for submitting Form N-648 are explained clearer for applicants and medical professionals. USCIS also revised the instructions so that they are clearer on how to complete the form.
- Medical professionals can focus their evaluation specifically on their medical diagnosis and not worry about the applicant’s daily activities, which may be irrelevant to the filing process.
- Medical professionals can complete the form electronically or on paper.
- Applicants are no longer required to report any previous disability evaluations from other government agencies.
- A certification section was included in the new, revised Form N-648, that interpreters, for applicants or medical professionals are required to prepare.
Form N-648 is for applicants who seek an exception to the English and/or civics requirements of the naturalization process due to a physical or developmental disability or mental impairment that has lasted or is expected to last twelve months or more. A Form N-648 applicant should submit Form N-648 at the time he or she files Form N-400, Application for Naturalization. Form N-648 applicants are not required to fulfill the English language and civics requirements if the applicant is unable to do so due to physical or mental disabilities. However, applicants who can meet the English and civics requirements but only with accommodations, should not use Form N-648. These applicants include those needing sign language or extended time for testing. It needs to be specifically noted that illiteracy alone is not a valid reason to seek an exception using the Form N-648.
Form N-648 must be certified by a licensed medical professional. Before certifying Form N-648, the medical professional must have conducted an examination of the applicant. Of course, it is always best for the medical professional to have had a significant history of care with the applicant. Medical professionals preparing the Form are advised that Form N-648 responses must be indicated in common language, without abbreviations, so that a person without medical training would be able to understand. Only medical doctors, doctor of osteopathy, or clinical psychologists licensed to practice in the United States may complete Form N-648.
The Adjudicatory Officers for the USCIS have also received more guidance about the Form N-648. The Adjudicator’s role is to determine whether the Form N-648 contains sufficient information to establish that the applicant is eligible for a disability exception under section 312 of the Immigration and Nationality Act (“INA”). The Adjudicator is supposed to focus on determining whether the medical profession