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Immigration Form N-648, Medical Certification for Disability Exceptions


In 1994, Congress enacted legislation providing an exception to the English and civics requirements for applicants who cannot meet them due to a medical condition or psychological impairment. As part of the naturalization process, the applicants typically should attend an interview scheduled with an immigration officer at a USCIS office and pass the citizenship exam before their citizenship application is approved to become a U.S citizen. The citizenship exam includes reading, writing, and communication tests in English, as well as the U.S history and civic tests. The applicant needs to answer 6 out of the 10 questions in order to pass the U.S history and civic test. 

Per this legislation, if an applicant presents with a medical or mental impairment that prevents him/her from learning the English language and/or U.S. history and civics, they have the option to request to be medically exempted from taking the citizenship exam. In order to do that, Under 8 CFR 312.2(b)(2), a medical doctor, doctors of osteopathy, and clinical psychologists are authorized to certify the disability exception form N-648, Medical Certification for Disability Exceptions, and attest that the applicant suffers from a medical or psychological condition, therefore making it impossible for she/he to take the citizenship exam. The applicant then files the form N-648 along with his/her citizenship application (N400) and if approved by the USCIS officer, he/she can become a U.S citizen without having to pass the citizenship exam. 

The burden of proof to demonstrate that there is a medical or psychological impairment, preventing the applicant to meet the citizenship requirement is placed on the applicant. Please note that per the USCIS, illiteracy or advanced age, in and of itself, is not a medical determinable physical and mental impairment that could give ground to being medically exempted from taking the citizenship exam. The Form N-648 should be completed by the certifying medical professional no more than 6 months before the applicant files the naturalization application in order to be accepted.

The applicants need to be evaluated by one of the authorized physicians listed above, and file the completed Form N-648 along with their naturalization application (N-400). The immigration officer then will have a chance to review the N-648 form prior to their scheduled interview. On some occasions, the applicants are provided with the opportunity to file the N648 at a later time, after they have filed their naturalization application. Each applicant is given only two chances to submit the N-648 form completed by a medical doctor or a clinical psychologist. If their N-648 form is denied by the USCIS officer both times, they will be required to file a new citizenship application and start the process all over again. Therefore, it is very important that the applicants choose the right physician to complete the N-648 form, who has extensive experience, familiarity, and knowledge of the immigration process and the USCIS’s specific requirements to properly complete the Form N-648. 

Per the N-648 review guidelines, it is unacceptable for the USCIS officer to determine the validity of the medical diagnosis or second guess the professional opinion of the physician who has completed the N-648 form for an applicant. They also cannot require an applicant to undergo medical, psychological, or laboratory diagnostic techniques to prove why they should be exempt from taking the English exam and U.S history and civic exam. This is the responsibility of the evaluating physician to attest that the applicant presents with a “medically determinable” physical or developmental disability or mental impairment that has lasted, or is expected to last at least 12 months, and they may qualify for the exception. 

An applicant who does not speak English is entitled to have an interpreter present at the time of his/her evaluation with a physician who is completing the N-648 form. They can also have an interpreter present at the time of their interview at a USCIS office. The interpreter can be a family member of the applicant or a certified interpreter, as long as they speak the applicant’s native language and the English language well. Per the N-648 guidelines, the same interpreter who assisted the applicant during his/her evaluation with a physician can also accompany them to their interview at a USCIS office. 

Dr. Neda Khodaparast Neda Khodaparast, PsyD, QME, is the founder and CEO of The Green Room Psychological Services Inc. in San Diego, California. Dr. Khodaparast earned her doctorate from the Massachusetts School of Professional Psychology in Boston. She has over 15 years in clinical practice providing individual and couple therapy, as well as conducting forensic evaluations for personal injuries, civil cases, immigration evaluations, and pre surgical clearance psychological evaluations. She has also been conducting medical-legal worker’s compensation evaluations as a Qualified Medical Evaluator (QME) Since 2014. Dr. Khodaparast specializes in utilizing psychodynamic orientation and focuses on treating trauma and PTSD including childhood sexual and physical abuse, sexual assualt’s survivors, war truama, as well as eating disorders, and adoption related issues. She appreciates the complexity of human’s psyche and understands the process and the importance of “meeting the patients where they at.”

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