The U.S. Citizenship and Immigration Services (USCIS) has announced significant revisions to the submission and review process for Form N-648, the Medical Certification for Disability Exceptions, effective immediately. The updated guidance, detailed in a policy alert (PA-2025-10) issued today, aims to enhance the integrity of the naturalization process by cracking down on fraudulent medical certifications that have historically undermined the system.
Form N-648 allows certain applicants for U.S. citizenship to request an exemption from the English language and civics requirements for naturalization if they have a medically determinable disability or impairment that prevents them from meeting these standards.
Established under the Immigration and Nationality Technical Corrections Act of 1994, the form must be completed by a licensed medical professional—such as a medical doctor, doctor of osteopathy, or clinical psychologist—who certifies that the applicant’s condition, expected to last at least 12 months, renders them unable to demonstrate proficiency in English, civics, or both.
However, USCIS claims that the medical certification process has been exploited over the years. Numerous cases have surfaced where medical professionals were arrested, indicted, or convicted for submitting fraudulent Forms N-648. For example, in United States v. Awaisi (2023), a Michigan doctor was convicted for creating 1,249 fraudulent certifications between 2016 and 2020.
Similarly, in USA v. Mendez-Villamil (2016), a Florida psychiatrist pleaded guilty to a scheme defrauding multiple federal agencies, including USCIS, by submitting over 3,000 false disability applications over 14 years. Such abuses, USCIS argues, not only weaken the credibility of the disability exception but also jeopardize the integrity of the entire naturalization system by allowing ineligible applicants to become citizens.
The revised USCIS guidance for Form N-648, effective June 13, 2025, introduces several critical changes to enhance the integrity of the naturalization process and combat fraud.
Firstly, USCIS has reinstated the pre-2022 requirement for applicants to submit Form N-648 concurrently with their Application for Naturalization (Form N-400), except in cases where extenuating circumstances justify a late submission. This aims to streamline processing and reduce opportunities for fraudulent claims.
Secondly, the submission of multiple Forms N-648 for a single applicant may now trigger heightened scrutiny, as it could indicate inconsistencies or questionable credibility in the disability claim, prompting further review.
Thirdly, medical professionals are required to provide a clear and detailed explanation of the nexus between the applicant’s disability or impairment and their inability to meet the English or civics requirements, ensuring certifications are specific and verifiable.
Additionally, the policy introduces explicit guidelines for identifying “credible reasons” to doubt a Form N-648’s validity, such as discrepancies in documentation or a medical professional’s history of fraud, enabling USCIS officers to better detect suspicious submissions.
Lastly, the review process has been refined to allow USCIS to request a supplemental Form N-648 from the same medical professional when a certification is deemed insufficient, balancing efficiency with rigorous oversight.
The USCIS Policy Manual, specifically Volume 12, Part E, Chapter 3, has undergone significant structural updates to reflect the revised Form N-648 guidance. A new section titled “Purpose” has been added to articulate the objectives of the medical disability exception and the need for enhanced fraud prevention measures, with subsequent sections redesignated accordingly.
The “Background” section has been retitled and updated to replace the phrase “physical or developmental disability or mental impairment” with the simpler “disability or impairment” for clarity. The filing section has been renamed “Submission of Form N-648,” with subsections reorganized into “Form N-648 Submitted Concurrently with Form N-400,” “Late Submissions,” and a fully revised subsection on “Multiple Submissions” to address credibility concerns.
The “Scope of Medical Examination” section has been updated with revised bullet points and a new paragraph to clarify examination requirements. The “Review of Medical Certification” section includes revised guidelines, updated tables, and a completely rewritten subsection on “Credible Reasons to Doubt the Validity of Form N-648,” alongside a new subsection on requesting supplemental forms.
The “Sufficiency of Form N-648” section has been streamlined, with revised paragraphs and bulleted lists, while the “Interview, Re-Examination, and Hearing” section incorporates prior footnotes into the main text for better accessibility. Minor technical revisions were also made to Volume 12, Part H, Chapter 2, regarding definitions of U.S. residence and physical presence, ensuring consistency across the manual.
In its policy alert, USCIS has emphasized that fraudulent certifications not only undermine the purpose of the disability exception but also compromise the credibility of the naturalization process, potentially allowing unqualified individuals to gain U.S. citizenship. By implementing these changes, USCIS aims to restore confidence in the system while continuing to provide a pathway to citizenship for those with legitimate disabilities.
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Kishor Panthi
View More PostsKishor Panthi is the founder and editor-in-chief of Khasokhas and NepYork. He is the author of three books, “Kampan,” "UNTRANSLATABLE" and “Zero Mile.” He writes about social issues, immigration, and politics.
