USCIS Tightens the Form N-648 Medical Disability Exception to the Naturalization English and Civics Test

Status: In effect now — USCIS N-648 Medical Disability Exception Tightening (Naturalization English/Civics Waiver) (USCIS Policy Alert, effective June 13, 2025 (Policy Manual Vol. 12, Pt. E, Ch. 3))

In effect. On June 13, 2025, USCIS updated its Policy Manual (Volume 12, Part E, Chapter 3) to tighten how it reviews Form N-648, the medical certification that can exempt a naturalization applicant from the English and civics test. The guidance applies to Form N-400 and any accompanying Form N-648 filed on or after June 13, 2025. It stresses that the certifying medical professional must explain how the disability or impairment leaves the applicant unable to meet the English and civics requirements — the presence of a disability alone is not sufficient — and treats submitting multiple Forms N-648 as a possible credibility concern that can trigger further review. USCIS framed the change as enhancing the integrity of the review process and preventing fraud, and tied it to Executive Orders 14148 and 14159.

Next step: No court or legislative deadline is pending — this is operative agency policy. Watch for any further USCIS Policy Manual revision, an updated Form N-648 or its instructions, or litigation challenging the tightened certification standard.

Verified against the primary source as of 2026-07-25 — status can change with a single court ruling. Official source.

What’s happening

In effect. On June 13, 2025, USCIS updated its Policy Manual (Volume 12, Part E, Chapter 3) to tighten how it reviews Form N-648, the medical certification that can exempt a naturalization applicant from the English and civics test. The guidance applies to Form N-400 and any accompanying Form N-648 filed on or after June 13, 2025. It stresses that the certifying medical professional must explain how the disability or impairment leaves the applicant unable to meet the English and civics requirements — the presence of a disability alone is not sufficient — and treats submitting multiple Forms N-648 as a possible credibility concern that can trigger further review. USCIS framed the change as enhancing the integrity of the review process and preventing fraud, and tied it to Executive Orders 14148 and 14159.

Who it affects

Lawful permanent residents applying to naturalize who seek a medical waiver of the English and civics tests using Form N-648 — often older or disabled green-card holders. Under the tightened standard, the medical professional (a licensed U.S. medical doctor, doctor of osteopathy, or clinical psychologist) must clearly connect the specific disability or impairment to the applicant’s inability to meet the English and civics requirements, even with reasonable accommodations. USCIS generally expects Form N-648 to be filed together with Form N-400 (rolling back an earlier allowance to file it later), and may flag duplicate or multiple N-648 submissions for closer fraud review. The exception itself remains available under INA § 312(b); what changed is how strictly the certification is scrutinized, which can affect the odds of approval for those relying on it.

How it got here

  1. Oct 19, 2022 USCIS shortened and simplified Form N-648, added telehealth guidance, and allowed the form to be submitted after Form N-400 — easing the disability-exception process for applicants with disabilities.
  2. Jun 13, 2025 USCIS issued a policy update (Policy Manual Vol. 12, Pt. E, Ch. 3) tightening review of Form N-648. Effective immediately, it applies to Form N-400 and any Form N-648 filed on or after this date, requires the medical professional to show a clear link between the disability and the inability to meet the English/civics requirements (disability alone is not enough), generally expects concurrent filing with Form N-400, and treats multiple N-648 filings as a possible credibility concern subject to further review.

What to watch next

No court or legislative deadline is pending — this is operative agency policy. Watch for any further USCIS Policy Manual revision, an updated Form N-648 or its instructions, or litigation challenging the tightened certification standard.

Official sources

This page is general information about ongoing litigation, not legal advice. A case’s status can change with a single ruling, and outcomes can turn on facts specific to each person. For advice on a specific situation, consult a licensed immigration attorney or a DOJ-accredited representative.