What Is Form N-648: Medical Certification for Disability Exceptions?

In a Nutshell

If you aren’t able to take the citizenship test required at your naturalization interview because of a medically diagnosed impairment or disability, you can let U.S. Citizenship and Immigration Services (USCIS) know ahead of your interview with Form N-648. This article explains what Form N-648 is, how USCIS uses it, and who’s eligible for the waiver. It also covers how to fill out the form and what happens if USCIS denies your application.

Written by Jonathan Petts
Updated July 11, 2022

What Is Form N-648 Used For?

Form N-648, Medical Certification for Disability Exceptions, is a waiver for certain applicants undergoing the citizenship interview through the U.S. naturalization process. Usually, applicants must prove they can read, write, and speak the English language. They also need to pass a U.S. history and U.S. civics test. This form allows people with diagnosed medical conditions to be exempt from these English and civics requirements. Applicants may receive reasonable accommodations, such as interviewing in their native language or not having to answer specific questions. 

Who Is Eligible for a Disability Waiver?

Only those with a physical or developmental disability are eligible. This disability must be verified by a medical professional, must harm the applicant’s ability to complete the naturalization interview, and must last at least 12 months. Illegal use of drugs cannot have caused the disability. Ilicit drug use can result in deportation. 

Who Can Fill Out Form N-648?

Only doctors can complete Form N-648. This includes medical doctors with an M.D., doctors of osteopathy with a D.O., and licensed clinical psychologists. The medical professional must must be licensed in the United States or U.S. territories, such as Puerto Rico, and must have performed an examination of the applicant. 

Staff members can help fill out the form. However, the completed form must be signed by the medical professional. 

How To Fill Out Form N-648

Form N-648 has six parts. Part 1 is information about the applicant, including their name, address, A-Number or Social Security number, and other information. Part 2 is information about the examining medical professional, including their name, address, and licensing information. Part 3 is where the doctor will attest to the applicant’s disability and explain the clinical diagnosis in everyday terms. 

They need to describe the origin of the medical disability or mental impairment. They also need to detail the specific symptoms that prevent the applicant from completing the naturalization interview. Finally, the doctor should conclude how the symptoms stop the applicant from learning English, civics, or both, using clear and definitive language certifying that the applicant cannot complete the exams. Their job is to prove you meet the eligibility requirements for a waiver. 

The doctor must complete the form by typing or writing in black ink. You should submit Form N-648 alongside Form N-400: Application for Naturalization. Otherwise, USCIS may reject Form N-648 as a late submission. 

Information About Disability and/or Impairments

There are 23 questions in Part 3 of Form N-648. Here is a sample of some of the questions in this section:

  • Question 1: The doctor should state the clinical diagnosis of the applicant with the relevant DSM and/or ICD codes.

  • Question 2: The doctor should provide a basic description of the disability, keeping in mind that the people who read USCIS forms are not medical professionals. 

  • Question 9: The doctor needs to explain the diagnosis process. This explanation should include any laboratory or clinical methods and their rules. If tests were not used, they should explain why tests were not medically appropriate. 

  • Question 10: The doctor should explain how the symptoms affect the patient’s ability to learn and remember new material or prove their knowledge. The doctor should conclude their description with a strong statement explaining that the disability causes the applicant’s inability to learn enough English and U.S. civics for the exam. Simply saying the patient has “difficulty” learning is not strong enough. 

Here are some symptoms that would be relevant to the exemption: 

  • Memory impairment 

  • Difficulties with concentration or focus 

  • Severe intellectual disabilities that affect reading and writing 

  • Paranoia, anxiety, hostility, or delusions that prevent the patient from expressing their learning 

  • Unpredictable behavior because of stress and anxiety that affect the patient’s ability to answer questions in a testing environment 

What Happens if USCIS Denies Your Form N-648 Application?

There are numerous reasons why USCIS may reject a waiver application. Make sure to check for the following: 

  • You submitted the correct edition of Form N-648.

  • You submitted the disability waiver simultaneously with your application for naturalization. 

  • The doctor completed all sections and required signatures. If a question does not apply, the doctor should write “N/A” or “none.” Otherwise, blank areas may be considered incomplete. 

  • The doctor clarified the connection between your symptoms and your inability to learn English or U.S. civics. The doctor should explain how the disability affects your daily life and provide detailed descriptions of its impact on your abilities. For example, the doctor cannot simply write, “Because the patient has dementia, they cannot learn English or U.S. civics.” They need to explain what dementia is. 

  • You did not exhibit any signs of fraud. The immigration officer who reviews your form may want to ensure that your claim is legitimate. They may ask for additional information such as: 

  • How did you find this doctor? 

  • How long have you seen this doctor?

  • What language do you use to communicate with the doctor? 

  • Did you use an interpreter to communicate with the doctor? If so, this should be the same person who signed the interpreter’s certification on your form. 

If USCIS denies your Form N-648, you must determine why. USCIS may reject you because your form is insufficient, not credible, fraudulent, or a misrepresentation. If your form is insufficient, the officer will proceed with your interview as usual. The officer will not waive the citizenship tests for you. You can choose to refuse to continue, but this refusal will count as a failed attempt to pass. 

You can also choose to submit more information. The immigration officer may re-examine your case. However, ensure this information is consistent with your other documents or they may see your application as fraudulent. 

The worst case scenario is if the officer thinks you or your doctor committed fraud or misrepresented your case. They might recommend your case to Fraud Detection and National Security Directorate (FDNS). If they determine fraud did occur, USCIS will explain that in your naturalization denial notice. This is very serious. You could face deportation for committing fraud.