August 12, 2025

New Policy Update on Disability Exceptions for U.S. Citizenship Applications (N400)

U.S. Citizenship and Immigration Services (USCIS) has issued new guidance to strengthen the way it reviews Form N-648, which is used to request an exception to the English and civics tests during the naturalization process due to a medical disability.

Generally, anyone applying for naturalization must show they understand the English language and have knowledge of U.S. history, government principles, and civics. In 1994, Congress created an exception for applicants who cannot meet these requirements due to a medically determinable physical or developmental disability or mental impairment.

The former Immigration and Naturalization Service (now USCIS) put this rule into effect under 8 CFR part 312 and introduced Form N-648 for applicants to request this exception. Form N-648 must be filled out and certified by a medical professional who confirms that the applicant has a medical condition lasting—or expected to last—at least 12 months, which prevents them from meeting the English or civics requirements, or both.

What’s Changing?

• Updates the process for reviewing medical certifications to improve integrity and strengthen fraud detection.
• Reinstates the pre-2022 policy requiring applicants to submit Form N-648 (Medical Certification for Disability Exceptions) at the same time as Form N-400 (Application for Naturalization), unless the applicant can show extenuating circumstances.
• States that submitting multiple Forms N-648 at once may raise credibility concerns and may trigger additional review.
• Emphasizes that the medical professional must clearly explain the link (the “nexus”) between the applicant’s disability and their inability to meet the English and civics requirements.
• Clarifies the policy on what may constitute credible reasons to doubt the validity of a submitted Form N-648.

Why the Change?

Over the years, some individuals and medical providers have misused the disability exception process. False certifications harm the naturalization system by allowing people to bypass the legal requirements unfairly.

Who This Affects:

Applicants for U.S. citizenship who:

• Have a physical, developmental, or mental disability that has lasted (or is expected to last) at least 12 months, and
• Are using Form N-648 to request an exemption from the English language and/or civics test.

Just having a disability is not enough to qualify for an exception. The medical professional must explain how the condition prevents the applicant from learning or demonstrating English and/or civics knowledge.

Follow Bailey Immigration for more information on Immigration updates and changes. Call our office for free consultation at (503) 224-0950.