Form N-648:
Medical Certification for Disability Exceptions
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If you’re applying for U.S. citizenship and a physical, developmental, or mental health condition prevents you from meeting the English and/or civics testing requirements, Form N-648 may allow an exception. Santana Residency Law helps clients throughout Miami and across the U.S. determine eligibility and prepare a complete N-648 submission.
This page is for general information only and is not legal advice.Call Santana Residency Law at 305-916-4800 to discuss your specific situation.
Who Can Certify Form N-648?
The form must be completed and signed by a licensed medical doctor, doctor of osteopathy, or clinical psychologist. The condition must last, or be expected to last, at least 12 months.
The certifying professional must address three things:
- Diagnosis — a plain-language explanation of the applicant’s illness or disability
- Origin — a simple explanation of how or when the disability began
- Nexus — a clear explanation of the symptoms that prevent the applicant from learning English and/or U.S. civics
What Qualifies for an N-648 Exception
To qualify, the condition must:
- Be diagnosed by a licensed medical or mental health professional
- Impact the applicant’s ability to meet citizenship testing requirements (this can include chronic medical conditions, mental health conditions, and/or cognitive impairments)
- Not be related to illegal drug use
If you can meet the English and civics requirements with reasonable accommodations, you should not submit Form N-648, the exception is only for applicants who genuinely cannot meet the requirements, not simply for extra support.
Important: Timing Requirement
Since a 2025 USCIS policy update, Form N-648 generally must be filed at the same time as your naturalization application (Form N-400), unless you can show extenuating circumstances for filing it later. Submitting multiple N-648s for the same applicant can also raise credibility concerns with USCIS. Planning this timing correctly with your attorney and medical provider from the start matters.
Note: USCIS has proposed further revisions to Form N-648 that, as of this writing, have drawn opposition from immigration advocacy groups and are not yet finalized.
What the Process Typically Looks Like
- Initial evaluation: a conversation with your medical or mental health provider about your medical history, symptoms, and how your condition affects daily life.
- Testing, if needed: depending on your condition, the provider may conduct assessments covering areas like memory, attention, reasoning, or emotional functioning (this step isn’t required for every condition — for example, a purely physical impairment may not require cognitive testing).
- Form completion: if the evaluation supports eligibility, the provider completes Form N-648, explaining your condition, its impact, and how it aligns with USCIS standards.
- Submission to USCIS: filed together with your naturalization application. USCIS reviews the form and decides whether to grant the exception.
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How Santana Residency Law Can Help
We help clients determine whether an N-648 exception fits their situation, coordinate timing with the right medical professional, and prepare a complete, well-documented naturalization filing.
No. A signed N-648 doesn't guarantee approval. USCIS officers independently review the form and decide whether to grant the exception based on the evidence provided.
If accepted, your naturalization interview will be in your preferred language. An interpreter will be provided if needed. USCIS will waive the requirement(s) your medical professional said you cannot meet: English test, civics test, or both.
If denied at the interview, USCIS proceeds as though you hadn't submitted an exception, and you'll be given the opportunity to complete the English and civics requirements.
USCIS only accepts an N-648 submitted with a citizenship application within 6 months of the certifying medical professional's signature.
Generally, yes. Since a 2025 policy update, USCIS requires N-648 to be filed concurrently with Form N-400 unless you can show circumstances for a later filing.
Only a licensed medical doctor, doctor of osteopathy, or licensed clinical psychologist authorized to practice in the U.S. or its territories can certify Form N-648.
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