October 9, 2025

Stricter USCIS Rules for Disability Exceptions in Naturalization Process (Form N-648)

On June 13, 2025, U.S. Citizenship and Immigration Services (USCIS) announced new policy guidance that significantly changes how it evaluates Form N-648, Medical Certification for Disability Exceptions, which is used by applicants seeking exemption from the English and civics requirements for naturalization. The update aims to strengthen the integrity of the process, reduce fraud, and ensure that only those who truly qualify receive this important exception. 

Over the years, USCIS has seen abuse of the disability exception process. Some medical professionals have submitted vague, incomplete, or even false certifications that do not clearly demonstrate how a disability prevents an applicant from learning or being tested on English or U.S. civics. These issues have led to USCIS mistakenly approving naturalization applications for individuals who did not meet all legal requirements for citizenship. USCIS wants to make sure that disability exemptions are used appropriately and not exploited by applicants or professionals who may misrepresent a condition.

What Has Changed?

The new guidance applies to all Form N-648s filed on or after June 13, 2025, and introduces several important changes:

• Stricter verification of medical claims: USCIS will more thoroughly evaluate whether the medical condition truly prevents the applicant from meeting naturalization requirements.
• More detailed medical explanations required: Doctors must explain exactly how the applicant’s disability or impairment limits their ability to learn English or U.S. civics.
• Disability alone is not enough: The mere presence of a medical condition does not qualify someone for an exemption. The condition must result in a functional limitation that affects learning or comprehension.
• More scrutiny of multiple submissions: If multiple Forms N-648 are submitted, especially with conflicting information, the application may be flagged for further review.
• The condition must be long-term: The disability or impairment must have lasted (or be expected to last) at least 12 months.

These changes are meant to prevent misuse of the system while ensuring that those with genuine, well-documented disabilities continue to receive fair consideration.

What Does This Mean for Applicants?

If you are applying for naturalization and cannot meet the English or civics requirements due to a physical or mental condition, it is still possible to qualify for an exception but now, the bar is higher. You will need to work closely with a qualified medical professional who can clearly explain how your disability affects your ability to meet these requirements.

Here are some tips for success under the new rules:

• Choose a medical provider familiar with immigration forms – Not all doctors are experienced in preparing Form N-648. Choose someone who understands the form’s legal standards.
• Be honest and consistent – Inconsistencies between multiple forms or vague descriptions may lead to delays or denials.
• Submit strong documentation – Supporting medical records can help show that the disability is serious, long-term, and genuinely limiting.

If you or a loved one needs help responding to a USCIS concern about a previous submission, don’t wait to get legal assistance. Mistakes can delay your case or even result in denial of your naturalization application.

Attorney Diana Bailey has over 26 years of experience in immigration law and has helped hundreds of clients with disability waivers, citizenship applications, and more. Our team at Bailey Immigration, PC can guide you every step of the way.

Call us today at (503) 224-0950 to schedule a consultation and ensure your application is handled with the care and precision it deserves.