Overview
Applying for U.S. citizenship typically involves showing proficiency in English and knowledge of U.S. civics. But what if you have a physical, developmental, or mental impairment that makes it difficult to meet these requirements?
The U.S. Citizenship and Immigration Services (USCIS) offers a Medical Disability Exception (Form N-648) for eligible individuals to be exempt from these requirements. This guide provides an overview of Form N-648, covering its purpose, application process, common issues, and tips for successful completion.
What is Form N-648?
Form N-648 is for naturalization applicants who cannot demonstrate English proficiency and knowledge of U.S. history and civics due to physical or mental impairments. This form explains why the applicant cannot meet these requirements because of their disability. A licensed medical doctor, doctor of osteopathy, or clinical psychologist must complete the form to request a medical exception.
Key Takeaways
- Purpose: Form N-648 helps applicants with disabilities seek exemptions from citizenship test requirements.
- Documentation: Detailed medical documentation is crucial to support the exemption request.
- Accuracy: Errors or incomplete information on Form N-648 can lead to delays or denial of the exemption.
Naturalization Requirements
Normally, naturalization applicants must learn 100 questions about U.S. civics and history and demonstrate English reading, writing, and speaking skills. However, applicants with impairments can request exceptions or accommodations to modify these requirements using Form N-648. USCIS provides these services to help individuals with disabilities navigate the naturalization process.
Quick Links & Resources
Accommodation vs. Exemption in Naturalization
In U.S. naturalization, accommodation and exemption are two different provisions for applicants with disabilities. It’s important for applicants and their medical professionals to understand the difference between these terms.
Accommodation
An accommodation means modifications or adjustments to the standard testing process to help applicants with disabilities show they can demonstrate English proficiency and knowledge of U.S. civics. Accommodations do not exempt applicants from the requirements but make the tests more accessible.
Examples of accommodations:
- Extended Time: Extra time to complete the English and civics tests.
- Sign Language Interpreters: Interpreters for applicants who are deaf or hard of hearing.
- Off-site Testing: Naturalization interview and tests at a location other than the standard USCIS office for applicants with mobility issues.
Applicants can request a disability accommodation online at uscis.gov/accommodations or by calling the USCIS Contact Center at 800-375-5283 (TTY 800-767-1833)
Exemption
An exemption is a complete waiver of the English and/or civics requirements due to a medically determinable physical, developmental or mental impairment. To request an exemption, applicants must submit Form N-648, Medical Certification for Disability Exceptions, completed by a licensed medical professional. The form must provide detailed information about the applicant’s disability, how it affects their ability to learn, and confirm that the impairment will last at least 12 months and is not due to illegal drug use.
Key Differences
Now that you understand the differences, applicants and medical professionals can navigate the naturalization process better and get the right support for those with disabilities.
Who is eligible for N-648 Disability Waiver?
To qualify for a disability waiver:
- The applicant has a medically determinable physical or developmental disability or mental impairment that prevents them from learning English and/or U.S. history and civics.
- The disability will last at least 12 months.
- The disability is not due to illegal drug use.
Guidelines for Completing Form N-648
Medical professionals must ensure their handwriting is legible, use black ink or type into the PDF form, and answer every question. The form must be single sided and provide a full explanation of how the impairment affects learning, reading, writing, or understanding English and U.S. civics.
Types of Qualifying Disabilities
Here are some examples of health issues that may be considered in Form N-648:
- Physical Disabilities:
- Mobility impairments affecting the ability to attend language classes.
- Visual or hearing impairments hindering comprehension of English or civics.
- Developmental Disabilities:
- Autism spectrum disorders impact social interaction and language learning. (Down syndrome)
- Intellectual disabilities affect comprehension of civic concepts.
- Mental Health Conditions:
- Severe anxiety disorders affect communication abilities. (Schizophrenia)
- Post-traumatic stress disorder (PTSD) impacting concentration and memory.
- Neurological Conditions:
- Stroke-related impairments affecting speech and cognitive functions.
- Traumatic brain injuries influence memory and language skills.
- Chronic Health Conditions:
- Chronic pain conditions affect concentration during language tests.
- Conditions requiring frequent medical treatments impacting study time (Chronic Obstructive Pulmonary Disease (COPD)).
Each case is unique, and the medical professional must clearly describe how these conditions specifically affect the applicant’s ability to meet English and civics requirements for naturalization
Old age, forgetfulness, unspecified learning disabilities, illiteracy, no formal education, and general correctable hearing/sight impairments do not qualify.
Age Waivers to Naturalization Test Requirements
Certain applicants meeting specific age and residency requirements can take an easier citizenship test:
- Age 50+ and 20 Years as Resident: Exempt from English test and civics test in their own language.
- Age 55+ and 15 Years as Resident: Exempt from English test and civics test in their own language.
- Age 65+ and 20 Years as Resident: Exempt from English test, simplified civics test in their own language (20 out of 100 questions).
Tips for Applicants
Here are some practical tips for applicants seeking a medical disability exception:
Before the Application
- Choose the Right Doctor: Ensure the medical professional is licensed and experienced in diagnosing and treating the disability.
- Fill out the Form Completely: Provide detailed information for all sections.
- Submit on Time: Submit Form N-648 with or shortly after Form N-400.
During the USCIS Interview
- Bring Supporting Documents: Have additional medical records or documents ready to support your case.
- Request an Interpreter: If needed, request an interpreter for the interview.
- Explain Discrepancies: Be prepared to explain any differences between submissions or records.
What Happens After Submitting Form N-648?
- Initial Review: Once USCIS receives your Form N-648, they will review it for completeness. If any required information is missing, your form may be considered insufficient.
- Additional Information Requests: USCIS may ask for more details or evidence to support your application. They might also request the originals of any documents you submitted copies of. If they ask for original documents, these will be returned to you once they are no longer needed.
- Decision Notification: The decision on your Form N-648 will determine if you qualify for an exception to the English and/or civics requirements for naturalization. USCIS will inform you of their decision in writing.
- Important: If USCIS issues a Request for Evidence, respond promptly with the required information. For complex cases or if you’re unsure how to proceed, consult an immigration lawyer for guidance.
Step-by-Step Guide for Medical Professionals
Fill out the Form N-648 correctly and completely to ensure the applicant gets the exemption from English and civics requirements for naturalization. One of the most common reasons for N-648 denial is the doctor failed to fill out the form properly.
Part 1: Applicant Information
- Full Name: Enter the applicant’s full legal name as it appears on their ID.
- Date of Birth: Provide the applicant’s birthdate in MM/DD/YYYY format.
- Alien Registration Number (A-Number): Enter the applicant’s A-Number, which can be found on their green card or other immigration documents.
Part 2: Medical Professional Information
- Your Information: Fill in your full legal name, business address, and contact number.
- Professional Title: Include your professional title (e.g., M.D., D.O., Clinical Psychologist).
- License Details: Enter your state license number and the state where you are licensed.
Part 3: Medical Diagnosis and Disability Information
- Clinical Diagnosis: Clearly state the clinical diagnosis of the applicant’s disability.
- Date of Examination: Record the date of the applicant’s last examination.
- Duration of Disability: Indicate whether the disability has lasted or is expected to last at least 12 months.
- Impact Description: Describe the disability in straightforward terms and explain how it affects the applicant’s ability to learn English and civics.
- Diagnostic Methods: Detail the specific clinical methods or tests used to diagnose the disability (e.g. MRI, psychological evaluation, physical exam).
Part 4: Certification
- Illegal Drug Use Statement: Certify the disability is not connected to illegal drug use.
- Medical Professional’s Certification: Read the certification statement and sign and date the form, certifying the accuracy of the information provided.
Part 5: Interpreter Information (if applicable)
- Interpreter Details: Include the interpreter’s full name, business address, and the language used during the examination.
- Interpreter’s Certification: The interpreter must sign and date the form to verify the accuracy of the translation.
- Note: For phone services, the medical professional fills out the interpreter’s biographic information but the interpreter does not need to sign the form.
Part 6: Additional Information
- Extra Sheets: Attach additional sheets if needed, ensuring each includes the applicant’s name and A-Number.
Best Practices for Medical Professionals
- Use Simple Language: Remember USCIS officers reviewing the form may not have medical expertise. Avoid medical jargon; explain the disability in clear, understandable terms.
- Provide Complete Details: Ensure every section is fully completed. Vague or incomplete answers can lead to denials.
- Specific Impact Description: Clearly state how the disability affects the applicant’s ability to meet English and civics requirements.
- Avoid Repetition: Customize each form to the individual applicant to avoid suspicion of fraud.
- Certify Accurately: Double-check all signatures, including those of interpreters, to ensure completeness.
Tips for Completing Form N-648
- Understanding Nexus: Nexusis crucial in Form N-648, referring to the connection between the applicant’s medical impairment and their inability to demonstrate English proficiency and knowledge of U.S. history and civics. To enhance approval chances, medical professionals must clearly articulate how the impairment directly impacts these areas.
- Addressing Multiple Health Issues: When applicants have multiple health issues, including physical or developmental disabilities, the combined effect can exceed the sum of individual impacts. Medical professionals should carefully assess and explain how these impairments collectively hinder the applicant’s ability to meet naturalization requirements.
- Providing Detailed Descriptions: For each health issue, describe the disability or impairment in detail, using simple language and no abbreviations or acronyms. Specify the clinical methods used for diagnosis and illustrate how each impairment affects daily activities and the ability to understand English and civics.
- Emphasizing Specificity: Medical professionals must avoid vague terms like “unlikely” or “probably” and instead provide explicit details regarding what the applicant can and cannot do. Ensure all relevant checkboxes on the form are checked accurately.
- Using the DONE Method: Remember the DONE when filling out Form N-648:
- Diagnosis: Clearly state the nature of the illness or disability in simple, understandable terms.
- Origin: Describe the cause of the disability, providing context for USCIS officers.
- Nexus: Explain how the symptoms of the disability directly prevent the applicant from learning English and/or U.S. civics.
- Effect: Conclude with a clear statement that the disability renders the applicant unable to learn English and/or U.S. civics due to its impact.
- Considering Medication Effects: Describe how any prescribed medication or treatment influences the applicant’s ability to learn or demonstrate knowledge. Clearly state if medication does not improve the applicant’s condition.
Important Note:
USCIS may not accept a Form N-648 if the certifying medical professional completed it more than 180 days before the submission of Form N-400. Ensure that your N-648 is up-to-date when you file your naturalization application.
Understanding USCIS Review Process
USCIS officers must thoroughly review Form N-648 to determine if the applicant is eligible for the medical disability exception. Here’s what officers should and should not do during this review:
What to Do
- Verify Completion and Certification: Ensure Form N-648 is fully completed, certified, and signed.
- Confirm Applicant’s Identity: Check that the form is for the applicant and that there are no significant discrepancies between Form N-648 and the applicant’s A-file or other records.
- Review Evidence: Ensure the form provides enough evidence to establish eligibility. This includes making sure the medical professional’s explanation is detailed and specific to the applicant’s disability or impairment.
What Not to Do
- Question the Medical Diagnosis: Officers should not validate the medical diagnosis or second-guess the medical professional’s assessment.
- Request Unnecessary Medical Records: Officers should not ask to see the applicant’s medical or prescription records without significant discrepancies.
- Mandate Specific Diagnostic Tests: Officers should not require the applicant to undergo specific medical, clinical or laboratory tests or methods.
- Doubt Based on Previous Disclosures: Officers should not conclude the applicant has not met the burden of proof solely because the medical condition was not disclosed in previous exams.
- Refer to Another Medical Professional Unnecessary: Officers should not refer the applicant to another medical professional just because the applicant was examined by a professional who speaks the same language, has the same culture, ethnicity or nationality.
Relationship Between Medical Disability and Educational Requirements
When reviewing Form N-648, officers must determine if the medical professional explains that the applicant’s disability prevents them from demonstrating required English language skills or knowledge of U.S. civics. Illiteracy or advanced age alone is not a valid reason for an exception. The impairment must affect the applicant’s ability to understand and use English, including reading, writing, and speaking, and/or know U.S. history and government.
Interpreters
Form N-648 Certification
If it’s unclear if an interpreter was used during the medical exam, officers should ask the applicant about the communication methods used. The medical professional must sign the interpreter certification if an interpreter was used. Telehealth exams do not require interpreter certification on Form N-648 but officers may question the interpreter if necessary and place them under oath.
Interpreter at Interview
Officers must use an interpreter to communicate with the applicant in their preferred language if there are questions about Form N-648 or if the form is incomplete. If the provided interpreter is disqualified, officers may use a language service or reschedule the interview so the applicant can find a new interpreter.
Reasons to Doubt the Form N-648
USCIS may find Form N-648 incomplete if there are credible reasons to doubt its validity, such as:
- The applicant was not examined by the certifying medical professional
- The medical professional is under investigation for fraud
- The interpreter involved in the exam is suspected of fraud
- Evidence of fraud or misrepresentation in the record
- Multiple Form N-648 submissions with different diagnoses
Officers must give the applicant an opportunity to explain during the interview. If necessary, officers may issue a Request for Evidence (RFE) or require a new Form N-648 from another medical professional but only with supervisory approval.
Most Common and Approvable Diagnoses for Cognitive Impairment
Dementia
Dementia is one of the most common and approvable diagnoses for cognitive impairment under Form N-648. Dementia is a general term for a decline in mental ability severe enough to interfere with daily life. Alzheimer’s is the most common type of dementia.
Key points to address in the Form N-648 for dementia include:
- Detailed Clinical Diagnosis: Include specific details about the type and severity of dementia.
- Cognitive Testing Results: Provide results from standardized cognitive tests.
- Impact on Daily Functioning: Explain how dementia affects the applicant’s ability to understand and respond to questions related to English and civics tests.
- Prognosis: Describe the expected course and outcome of the condition.
Intellectual Disability
Intellectual Disability is another common diagnosis that that can support a Form N-648 request. It involves significant limitations in both intellectual functioning and adaptive behavior, covering social and practical skills.
Key points to address in Form N-648 for intellectual disability include:
- Standardized IQ Test Scores: Provide scores from recognized IQ tests.
- Adaptive Behavior Assessments: Include assessments of social and practical skills.
- Specific Limitations: Explain how the disability affects learning and understanding.
USCIS Views on Depression Diagnoses
Major Depressive Disorder (MDD)
While depression is a recognized mental health condition, USCIS requires substantial evidence to grant a medical disability exception based on mental health conditions including depression. Major Depressive Disorder (MDD) must be severe and debilitating to qualify for an exemption.
- Severity of Symptoms: Document the severity and frequency of depressive episodes including any psychotic features.
- Impact on Cognitive Functioning: Explain how depression specifically affects the applicant’s cognitive abilities and ability to learn or test in a testing environment.
- Treatment History: Provide detailed treatment history including hospitalizations, medications and therapy.
- Comorbid Conditions: Mention any comorbid conditions that may worsen the symptoms of depression and affect the applicant’s functionality.
Common Reasons for RFE or Denial of Form N-648
RFE (Request for Evidence)
- Incomplete or Missing Information: The primary reason for receiving an RFE is incomplete or missing information on Form N-648. Ensure all sections are fully filled out and provide detailed explanations where required.
- Lack of Specificity: RFEs may be issued if the medical professional’s explanation of how the disability affects the applicant’s ability to meet English and civics requirements is vague or overly general.
- Discrepancies: Significant discrepancies between multiple submissions of Form N-648 or inconsistencies with other records can trigger an RFE.
- Missing Signatures: All required signatures, including the medical professional and interpreter (if applicable), must be on the form.
Denial
- Non-Compliance with RFE and NOID: Failure to respond adequately to RFEs (Request for Evidence) or NOIDs (Notice of Intent to Deny) or providing insufficient responses can lead to denial of Form N-648.
- Unresolved Discrepancies: Persistent unresolved discrepancies between Form N-648 and other records or multiple form submissions will result in denial.
- Fraud: Evidence indicating fraud or misrepresentation by the applicant, medical professional, or interpreter will lead to immediate denial.
- Insufficient Evidence: If the submitted evidence does not clearly demonstrate how the applicant’s disability prevents them from meeting English and civics requirements, a NOID may be issued, potentially leading to denial.
What if Form N-648 is Denied?
Initial Interview
If Form N-648 is found deficient during the initial interview but the applicant meets English and civics requirements, the officer will proceed with the rest of the naturalization interview to assess other eligibility criteria. The officer should not automatically assume fraud or lack of good moral character solely based on the deficiency of the N-648. However, further questioning regarding the reasons for the form’s deficiencies may follow.
Failing English and Civics Requirements
If Form N-648 is found deficient and the applicant does not meet English or civics requirements, the officer will issue a written notification listing the deficiencies. The applicant will be scheduled for a re-examination typically 60 to 90 days after the initial examination to provide an opportunity to meet the requirements.
Re-Examination
During the re-examination, if the applicant submits new information in support of Form N-648, the officer will review this evidence alongside the original form and supporting documents. If the applicant either fails any part of the test again or refuses to take it, the officer must deny the naturalization application due to the applicant’s failure to meet the English or civics requirements.
Hearing on Denial
In case of denial, the applicant can file a Request for a Hearing on a Decision in Naturalization Proceedings (Form N-336) within 30 days of the denial. USCIS may conduct a full de novo hearing and review any previously submitted Form N-648 and other relevant records. At the hearing, the applicant may present additional evidence, including a new Form N-648, to support their case.
Form N-648 Fraud and Criminal Charges
Fraud
Form N-648 fraud involves instances where medical professionals falsify diagnoses or provide false information to assist applicants in obtaining naturalization exemptions unlawfully. This fraudulent activity not only undermines the integrity of the naturalization process but also harms the applicants involved.
Criminal Charges
Several cases have emerged where doctors faced criminal charges for fraudulent completion of Form N-648. These charges typically include immigration fraud, perjury, and conspiracy. Physicians accused of falsely claiming that applicants had disabilities preventing them from meeting naturalization requirements have faced severe consequences, including imprisonment and revocation of their medical licenses.
Protect Yourself from Scams
USCIS aims to protect you from immigration scams, especially those involving fraudulent medical certifications for disability exceptions. Criminal cases have been prosecuted against individuals like Dr. Chilakamarri Ramesh, Habeeb Malik, Dr. Ira Weiner, Dr. Thongchai Vorasingha, Dr. Roberto J. Velasquez, Dr. Fernando Mendez-Villamil, and Julia Nguyen for such frauds.
Here are some important points to remember when seeking a medical certification for a disability exception:
- No Filing Fee for Form N-648: Although there’s no fee to file Form N-648, medical professionals may charge for examinations and completing forms.
- Authorized Medical Professionals Only: Only licensed medical doctors, doctors of osteopathy, or clinical psychologists in the U.S. can certify Form N-648. Verify their license through your state medical board.
- Proper Evaluation: The medical professional must evaluate you in person or through a real-time telehealth examination (if allowed by state law) and diagnose a condition that prevents you from meeting the educational requirements.
- Attestation/Release of Information: Ensure you read and sign the Applicant’s (Patient’s) Attestation/Release of Information. If you cannot sign due to a disability, a legal guardian, surrogate, or designated representative can sign for you.
For more information and resources to avoid scams, visit the Avoid Scams page on the USCIS website.
Although filing Form N-648 can often be straightforward, the consequences of errors or misunderstandings can be significant. To ensure your application is accurate and to avoid any potential issues, it’s highly recommended to consult with a knowledgeable attorney or a qualified professional before submitting your form.
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