Information for Medical Professionals Completing Form N-648

About Form N-648

Naturalization applicants with a physical or developmental disability or mental impairment may seek an exception to the English language and civic requirement(s) for naturalization .

In order to obtain an exception, an authorized medical professional must determine that the applicant’s disability renders them unable to learn or demonstrate a knowledge of English or U.S. civics or both. To allow the applicant to request a waiver, an authorized medical professional must complete Form N-648, Medical Certification for Disability Exceptions.

Illiteracy is insufficient, by itself, to support an exception to the English and civics requirements.

The purpose of this page is to summarize the main points covered by Form N-648 and its  accompanying instructions (PDF, 343.07 KB), and provide additional information for medical professionals to consider when completing the form.

Authorized Medical Professionals

USCIS only authorizes the following licensed medical professionals to certify the disability exception form:

• Medical doctors;
• Doctors of osteopathy; and
• Clinical psychologists.

Summary of Form N-648

When completing Form N-648, the medical professional needs to:

1. Conduct an in-person examination or, where the state law permits, a real-time telehealth examination of the applicant and verify the applicant’s identity;
2. Identify and describe the applicant’s physical or developmental disabilities or mental impairments that impact the applicant’s ability to learn English or civics;
3. Include any and all medically acceptable clinical or laboratory diagnostic techniques or methods you used to diagnose each of the applicant’s disabilities or impairments;
4. Explain, in common terminology that a person without medical training can understand, how the disability or impairment(s) prevents the applicant from learning or demonstrating the knowledge of English and U.S. civics, particularly focusing on the connection between the physical or developmental disability or mental impairment(s) and the applicant’s inability to demonstrate knowledge of English and U.S. civics;
5. Indicate whether the physical or developmental disability or mental impairment(s) has lasted or is expected to last at least 12 months;
6. Indicate whether any of the physical or developmental disabilities or mental impairments are the result of the illegal use of drugs;
7. Indicate whether the applicant is unable to understand or communicate the meaning of the Oath of Allegiance;
8. Indicate whether an interpreter was used during the medical examination;
9. Agree to provide medical records to USCIS if requested; and
10. Sign and certify the Form N-648.

Distinguishing a N-648 From a Reasonable Accommodation Request

There are applicants whose disabilities do not render them unable to learn or demonstrate knowledge, but make it difficult to learn or demonstrate knowledge. USCIS will not grant such applicants an exception of the English and U.S. civics testing requirements where USCIS can provide a reasonable accommodation. Under the law, an applicant’s difficulty in fulfilling the testing requirements on other bases is not sufficient to warrant an exception. Instead, the applicant may be eligible under the Rehabilitation Act for a reasonable accommodation to fulfill these requirements. An accommodation simply modifies the manner in which an applicant meets the educational requirements; it does not exempt the applicant from the English or civics requirements.

A Form N-648 is not required for accommodation requests. If your patient falls within these parameters, you should not complete Form N-648. Applicants who are unable to complete the English and civics exams due to a physical or developmental disability or mental impairment, must submit Form N-648 to request an exception from the English and civics requirements.

Additional Background Information

The following are examples of accommodations and modifications for the English and U.S. civics tests:

• Extended examination time and breaks;
• Sign language interpreters for deaf or hard of hearing applicants;
• Oral examinations for applicants with physical impairments, including limited use of hands if they cannot write sentences; and
• Large print or braille for applicants who have low vision or are blind or deafblind.

Resources

• USCIS Policy Manual Volume 12, Part C, Accommodations [12 USCIS-PM C].
• USCIS Policy Manual Volume 12, Part E, English and Civics Testing and Exceptions [12 USCIS-PM E].