Form N-648 guide: Medical Certification for Disability Exceptions

Wang Law Firm, LLC · David Wang, Managing Attorney · Attorney-reviewed · Updated October 2026

Form N-648's official title is Medical Certification for Disability Exceptions. U.S. Citizenship and Immigration Services (USCIS) reviews it together with the naturalization application, Form N-400. It is a medical certification completed by a licensed medical professional explaining that, because of a physical, developmental or mental impairment, the naturalization applicant cannot learn or demonstrate knowledge of English and / or U.S. history and government, and requesting an exception from the English portion, the civics portion, or both portions of the naturalization test.

Form N-648 is only an attachment to the naturalization application and cannot be filed on its own; under the current fee rules (8 CFR 106.2), there is no separate filing fee for Form N-648 itself. Even with an exception, the applicant must still meet all other naturalization requirements, such as years as a green card holder, continuous residence, physical presence and good moral character, and must be able to understand the meaning of the oath (or obtain a separate waiver of the oath).

At a glance

Who may need Form N-648

• People with conditions affecting learning, memory or cognition, such as moderate or more severe cognitive impairment or developmental disabilities, who have been diagnosed as truly unable to learn English or civics;
• People whose language, comprehension or memory has been impaired by a stroke, brain injury or similar condition;
• People with serious mental illness that prevents them from learning or demonstrating the required knowledge;
• Other medically confirmed physical or mental impairments that cause functional limitations.

In the following situations Form N-648 is generally not needed or not applicable:

• Being elderly, having limited education or being unable to read, without a medical impairment: this does not qualify for a disability exception. Check whether you qualify for the statutory age-and-years exceptions: if, at the time of filing, you are 50 or older and have held a green card for 20 years, or 55 or older and have held a green card for 15 years, you are exempt from the English test and may take the civics test in your native language; if you are 65 or older and have held a green card for 20 years, you may take a simplified civics test. These exceptions do not require Form N-648.
• Only needing an accommodation at the interview (for example, a sign language interpreter for a hearing impairment, or accessible facilities for limited mobility): request an accommodation on Form N-400 rather than filing Form N-648.
• A short-term impairment, such as a brief recovery after surgery: the regulations require that the impairment has lasted or is expected to last at least 12 months.

Legal basis and requirements for the exception

The English and civics requirements are in section 312(a) of the Immigration and Nationality Act (INA); the disability exception is in INA 312(b)(1) and 8 CFR 312.1(b)(3) and 312.2(b). USCIS's standards are in Volume 12, Part E, Chapter 3 of the Policy Manual. The core requirements:

1. A medically determinable physical or mental impairment, or a combination of both, that can be determined through clinical or laboratory diagnostic techniques;
2. The impairment has lasted or is expected to last at least 12 months;
3. The impairment means the applicant is unable, even with reasonable effort or accommodations, to demonstrate English ability and / or civics knowledge;
4. The medical professional must explain the causal link (nexus) between the impairment and the inability to meet the test requirements. Stating only the diagnosis without explaining why it prevents learning is the most common problem with Form N-648.

The regulations are clear that the impairment cannot be the direct result of illegal drug use.

Who can sign Form N-648

Under current rules, only these three types of licensed medical professionals can complete and sign Form N-648:

• A licensed medical doctor (MD);
• A licensed doctor of osteopathy (DO);
• A licensed clinical psychologist.

They must be licensed in a U.S. state, the District of Columbia or a U.S. territory. Nurses, nurse practitioners (NPs), physician assistants (PAs), traditional Chinese medicine practitioners, social workers, physicians practicing outside the U.S. and others cannot sign Form N-648 (they can provide other supporting medical records).

In practice, a certification signed by a treating physician or specialist who has known the applicant's condition for a long time is usually more persuasive. Signing by a doctor seeing the applicant for the first time is not prohibited, but if the diagnosis lacks support, the officer may have reasonable doubts.

New rules since June 2025: file with Form N-400

On June 13, 2025, USCIS issued a policy alert updating the Policy Manual and tightening the filing and review rules for Form N-648. The changes apply to Form N-400 applications, and accompanying Forms N-648, filed on or after that date. The main changes:

• Filed together: Form N-648 generally must be filed with Form N-400. If it is submitted after Form N-400 is filed (including at the interview), the applicant must show extenuating circumstances, or USCIS may not accept it.
• Multiple Forms N-648: submitting more than one Form N-648 for the same applicant may raise credibility concerns and lead to further review, especially if they contradict each other.
• Stricter review: officers examine the basis for the diagnosis, the degree of functional limitation, and the causal link between the impairment and the inability to pass the test more closely; USCIS's policy lists situations that may give reason to doubt a certification's credibility, such as a vague explanation by the doctor or contradictions with other evidence.

In addition, on August 29, 2025, USCIS published a proposal to revise Form N-648 itself (for example, adding questions about the impairment, treatment and daily activities, and requiring an in-person examination), and in June 2026 opened an additional 30-day comment period (through July 6, 2026); the new form is not yet in use. As of this writing, use the current form edition published on the USCIS official page. This area has changed often in recent years; verify the latest rules before filing.

Tips for each part of the form

Most of Form N-648 is completed by the medical professional; the applicant and interpreter sign only certain parts. Follow the part numbering in the current edition.

1. Applicant information and authorization (completed by the applicant)

• Your name, A-Number, date of birth and other details must match Form N-400 exactly.
• The applicant signs an authorization allowing the medical professional to disclose relevant medical information to USCIS. If the applicant cannot sign because of the impairment, follow the form instructions.

2. Medical professional information

• License type, license number, issuing state, practice address and contact information.
• Relationship with the applicant: whether the professional is the treating physician, how long he or she has treated the applicant, and the dates and methods of examination.

3. Diagnosis and description of the condition (the core section)

• Diagnosis: state the specific medical diagnosis, ideally with the standard diagnostic code, and the clinical methods, examinations or tests used to make it (for example, cognitive assessments or imaging results).
• Onset and duration: explain when the impairment began and whether it has lasted or is expected to last at least 12 months.
• Severity and functional limitations: explain in plain language how the impairment affects the applicant's ability to learn, remember, understand or express, rather than simply listing conditions.
• Causal link: clearly explain why the impairment makes the applicant unable, even with effort, to learn or demonstrate English and / or civics knowledge. This is the officer's main focus; the more specific, the better.
• Scope of the exception: state whether the request is for English, civics, or both. If the impairment affects only reading and writing and not speaking, say so accurately.

4. Medical professional's statement and signature

The medical professional must certify that the information is true and sign by hand. Whether an examination by telehealth is acceptable depends on the rules of the state of licensure and current USCIS policy; USCIS has proposed requiring an in-person examination in the new edition of the form, so verify before filing.

5. Interpreter's statement

If an interpreter was used between the doctor and the applicant during the examination, the interpreter must complete the relevant statement.

Evidence and supporting documents

• The completed and signed original Form N-648 (filed with Form N-400);
• Medical records supporting the diagnosis: outpatient notes, specialist examination reports, cognitive assessment results, hospital records, medication records and so on (not mandatory, but they usually help establish credibility);
• If you were treated in China or another country, those medical records need a complete English translation and a translator's certification; see Translation requirements for immigration applications;
• If you need an accommodation at the interview, note it on Form N-400 and provide an explanation.

Note: the officer will compare Form N-648 with Form N-400, past immigration medical exam records (such as Form I-693) and how the applicant performs at the interview. For example, if Form N-648 says the applicant cannot understand simple questions, but at the interview the applicant fluently answers questions about work and travel, that may raise doubts.

What happens at the interview

1. The officer first reviews whether Form N-648 is sufficient, taking into account the entire application and observations at the interview.
2. If Form N-648 is found sufficient, the applicant is excepted from the relevant portion(s), and the interview continues to review the other requirements.
3. If Form N-648 is found insufficient, the officer may request more evidence or have the applicant take the portion of the test he or she hoped to be excepted from; if the applicant fails, a retest is scheduled under the testing rules.
4. Even with an exception from the English test, the interview itself still takes place. The applicant may bring a qualified interpreter.
5. After approval, the applicant must be able to understand and recite the oath of allegiance; an applicant who cannot understand the oath because of an impairment may be eligible for a separate oath waiver process, which needs its own assessment.

For processing times, check the official USCIS processing times. For responding to an RFE, see What to do when you receive an RFE.

Common reasons Form N-648 is questioned or rejected

• Only the diagnosis is listed, without explaining how the impairment prevents learning or demonstrating knowledge;
• The basis for the diagnosis is unclear, with no explanation of the examination methods;
• Form N-648 contradicts other information on Form N-400 or the immigration medical exam record, for example claiming years of severe cognitive impairment while the applicant still does complex work;
• The signer is not qualified (not an MD, DO or licensed clinical psychologist);
• The impairment has lasted less than 12 months;
• It was submitted after Form N-400 was filed without showing extenuating circumstances;
• Multiple contradictory Forms N-648 were submitted.

A finding that Form N-648 is insufficient is not in itself a separately appealable decision. If Form N-400 is ultimately denied because the applicant failed the test, the applicant can file Form N-336 within the deadline to request a hearing, or refile Forms N-400 and N-648 once the medical evidence is complete.

Form N-648 compared with other exceptions and accommodations

Frequently asked questions

Official sources

• USCIS: Form N-648, Medical Certification for Disability Exceptions
• USCIS Policy Manual, Volume 12, Part E, Chapter 3: Medical Certification for Disability Exceptions
• 8 CFR Part 312: English and civics requirements
• USCIS: Form N-400

Related reading

• Form N-400 guide: Application for Naturalization
• Civics test practice (2025 version)
• From green card to citizen: N-400 requirements and process
• Form N-336: requesting a hearing after a naturalization denial

This article is general information and is not legal advice. Laws and policies can change; rely on the latest official information and on an attorney's advice for your specific situation.