Form N-648: A Guide

If you plan to apply for U.S. citizenship, the chances are high that you must have heard of Form N-648. So, what is it, and who is required to apply? Let’s find out.

What Is Form N-648?

Anyone applying for U.S. citizenship (naturalization) has to undergo a test/examination of the English language, U.S. History, and civic requirements. However, a person is granted an exception if they have a mental, physical, or developmental disability.

The United States Citizenship and Immigration Services (USCIS) is open to accepting a doctor’s certificate to exempt a person from taking the citizenship exams. This is done by completing Form N-648, also referred to as the Medical Certification for Disability Exceptions, to apply for the disability waivers for applicants who are medically impaired.

Who Qualifies for Form N-648?

Federal regulations in 8 C.F.R. 312.1(a)(3) allow exemption from the literacy prerequisite and 8 C.F.R. 312.2(b) gives leeway with respect to the civics requirement only if the person has “medically determinable physical or mental impairment or combination of impairments which has lasted or is expected to last for 12 months.”

The term medically impaired is defined as “an impairment that results from anatomical, psychological, or physiological abnormalities which can be shown by medically acceptable clinical or laboratory diagnostics techniques to result in functioning so impaired.”

It, however, does not apply to any impairment, physical or mental, caused due to illegal abuse of drugs.

Information for Completing Form N-648

While filling out the form, there are certain parameters a medical professional needs to follow:

• Establish and certify the diagnosis of the applicant.
• Explain the diagnosis using/citing any/all medically acceptable tests or methods.
• Establish and explain the relationship between the applicant’s disability and their inability to learn and appear for the literacy exam.

In addition, if the disability of the applicant doesn’t render them incapable to learn or demonstrate knowledge but makes it increasingly difficult, the USCIS will not extend the exemption. These applicants can apply under the Americans with Disabilities Act or the Rehabilitation Act.

Form N-648 Approval and Denial

Once Form N-648 has been completed and submitted for review, it is first taken under consideration by the interviewer while interviewing the applicant. Once the naturalization interview is over then the USCIS takes over. The approval or denial of the application depends on several things as mentioned below.

Did You Submit the Right Edition of the Form?

It is important to ensure that the form provided to you or you have downloaded from the USCIS website is the latest version. In some cases, the USCIS has rejected older versions of the forms. To check and download the latest version of Form N-648 visit www.uscis.gov/n-648.

Did the Doctor Fill Out the Form Completely?

Form N-648 requires the doctor to certify the disability of the applicant and thus it becomes one of the most important sections scrutinized by the immigration officer who receives the form. The officer will go through all the sections to ensure that they are filled out properly and have all the necessary signatures in place. If any information provided is either incomplete or wrong, the officer then has the right to reject the application.

Is the Connection (“Nexus”) Clear?

Once it is clear that all the documents and signatures pertinent to the disability case are in place, the officer will then verify if the doctor has clearly stated the connection between the applicant’s disability and their inability to learn English, U.S. History, or civics.

There is no room for obvious assumptions on behalf of the doctor. The doctor has to succinctly explain how and why the disability is affecting the applicant’s learning capability.

Does the Form or Applicant Exhibit Any Indications of Fraud?

Since, in these cases, there is a high probability for the occurrence of fraud, the officer takes several measures to ensure that doesn’t happen. The officer may ask questions such as:

• The duration of the doctor-applicant relationship.
• How did the patient/applicant come to know the doctor?
• What is the language of conversation between the doctor and the applicant?
• Was an interpreter required during the appointments?

This is to evaluate if there is even an iota of discrepancy in the application.

What the USCIS Officer Should Not Do: Act Like a Doctor

While the immigration officer possesses all rights to carefully examine the form and cross-examine the applicant, they are in no way are entitled to act in the capacity of a doctor. This means they are not allowed to ask questions that do not fall under the purview of the application. For example, the officer cannot ask the applicant how their disability affects their daily life or how they handle daily situations.

If the applicant’s attorney/interpreter feels that the immigration officer has wrongly disqualified the applicant, for a medical waiver based solely on their ability to perform a daily task, they can then ask for a hearing in front of a supervisor.

The officer cannot ask the applicant to undergo a certain test or examination or present a valid proof of prescription medications. In such cases, the applicant can ask to see a supervisor to present their case.

Conclusion

Form N-648 is a great help if you have requested a disability waiver while applying for U.S. citizenship for a relative. However, keep in mind that this is a very technical form and must be completed and submitted clearly and honestly. Any faults and gaps in the application might lead to the disqualification of the applicant.

Frank Gogol

I’m a firm believer that information is the key to financial freedom. On the Stilt Blog, I write about the complex topics — like finance, immigration, and technology — to help immigrants make the most of their lives in the U.S. Our content and brand have been featured in Forbes, TechCrunch, VentureBeat, and more.

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