The U.S. Citizenship and Immigration Services (USCIS) has announced the implementation of updated policy guidance aimed at reinforcing the credibility of the Form N-648 process, which grants exceptions to the English and civics requirements for naturalization based on medical disabilities.
This newly issued guidance marks a significant shift in how Form N-648, the Medical Certification for Disability Exceptions, will be evaluated. With a sharper focus on the authenticity of medical documentation and the detection and prevention of fraudulent submissions, USCIS is seeking to safeguard the integrity of the naturalization system. The updated policy reflects concerns that, over the years, certain individuals and medical practitioners have misused the certification process.
Highlighting the importance of the changes, USCIS noted, “Across the country and over the decades, there have been numerous instances where the medical certification process has been exploited.” The agency further stated, “When a medical professional provides a false certification, it not only undermines the purpose of the disability exception but also weakens the credibility of the entire naturalization system because it causes USCIS to naturalize aliens who have not established eligibility for naturalization.”
By default, individuals applying for U.S. citizenship are required to demonstrate proficiency in the English language, as well as a foundational understanding of U.S. history, government, and civic principles. However, applicants suffering from certain physical or developmental disabilities, or mental impairments, may qualify for an exemption from these requirements. To be eligible for such an exemption, applicants must file Form N-648, which documents and confirms their medical condition. This form must be completed and signed by a licensed medical professional who has personally evaluated the applicant.
The updated guidance stipulates that it is not enough for an applicant to simply be diagnosed with a disability. The medical professional must clearly articulate how the specific condition hinders the applicant’s ability to comply with the English and civics testing requirements. As the USCIS emphasized, “The presence of a disability alone is not sufficient.” Rather, the medical certification must directly link the disability or impairment to the applicant’s inability to meet naturalization criteria.
Additionally, the new policy takes aim at practices that may raise red flags for potential fraud. For example, the concurrent submission of multiple Forms N-648 for a single applicant is now flagged as a matter of concern. “Submitting multiple Forms N-648 concurrently may raise concerns about the credibility of the disability or impairment claim and could be subject to further review,” the guidance notes. This measure is designed to deter individuals from attempting to manipulate the process by seeking out multiple or conflicting medical opinions in hopes of receiving a favorable outcome.
This policy change is not an isolated action but part of a broader initiative aligned with recent executive orders aimed at strengthening the integrity of immigration processes. Specifically, the USCIS guidance is in accordance with Executive Order 14148, titled Initial Rescissions of Harmful Executive Orders and Actions, and Executive Order 14159, Protecting the American People Against Invasion. These directives reflect the current administration’s intent to reverse policies deemed detrimental to immigration accountability and national security, and to prioritize lawful and transparent procedures.
According to USCIS, the updated guidance is being integrated into Volume 12 of the USCIS Policy Manual, which deals specifically with citizenship and naturalization. Importantly, these changes are effective immediately. The guidance will apply to all naturalization applications and associated Form N-648 submissions made on or after June 13, 2025.
By reinforcing these procedures, USCIS is seeking to bolster public confidence in the naturalization process, ensuring that only eligible individuals benefit from exemptions. This change, the agency suggests, will help uphold the legitimacy of the nation’s immigration system, protecting it from abuse while continuing to provide accommodations for genuinely deserving applicants.
In essence, the revised guidance strives to strike a balance between compassion and compliance. It allows exemptions for individuals with legitimate medical conditions but simultaneously introduces necessary safeguards to deter misuse. USCIS’s actions demonstrate its ongoing commitment to maintaining the integrity and fairness of the U.S. naturalization process while guarding against vulnerabilities that could be exploited.
The decision to intensify scrutiny over the medical certification process reflects broader immigration enforcement trends. By targeting weaknesses in the system, such as fraudulent documentation and misleading medical claims, the agency is aligning its procedures with national priorities focused on lawful conduct and eligibility verification.
Overall, this policy aims to refine the naturalization application process by ensuring that disability waivers are granted only when justified by clearly documented and well-explained medical evidence. With the introduction of this guidance, USCIS is signaling a firm stance on preventing abuse of legal pathways to citizenship while remaining committed to upholding the rights of applicants with legitimate medical needs.
By doing so, the agency hopes to prevent further erosion of trust in the system and ensure that exemptions are based on factual and thoroughly verified claims. It serves as a reminder to both applicants and medical professionals that integrity and accuracy in documentation are not optional but essential to the process.
In conclusion, USCIS’s new policy guidance on Form N-648 marks a pivotal step in enhancing the oversight and reliability of medical disability certifications in the naturalization process. By tightening the requirements for documentation, addressing concerns about potential fraud, and supporting the current administration’s executive directives, the agency aims to protect both the credibility of the naturalization system and the rightful claims of individuals who genuinely qualify for such exceptions.