USCIS Tightens Disability Exemption Rules for Naturalization

“The presence of a disability alone is not sufficient to qualify for the exception. The applicant must demonstrate how the disability or impairment affects their ability to demonstrate knowledge and understanding of English and/or civics.” 

— USCIS Policy Manual, Vol. 12, Part E, Ch. 3 (Updated June 13, 2025)

On June 13, 2025, U.S. Citizenship and Immigration Services (USCIS) announced major revisions to how it handles Form N-648, the Medical Certification for Disability Exceptions. This form allows certain applicants for naturalization to request an exemption from the English language and U.S. civics testing requirements based on physical or developmental disabilities or mental impairments.

The new policy increases scrutiny of these exemptions and is particularly relevant for older adults and individuals with serious long-term health conditions who may face barriers to learning or memory.

What Has Changed?

1. N-648 Must Now Be Filed with the N-400

USCIS has reversed its 2022 policy that allowed Form N-648 to be submitted at any time during the naturalization process. As of now, the form must be filed at the same time as Form N-400, unless there are clear and compelling circumstances (such as a new diagnosis or a worsening medical condition).

2. Stricter Medical Documentation Requirements

Medical professionals can no longer submit vague or generic diagnoses. They must provide a detailed explanation of:

• The diagnosis,

  
  

• The onset and duration of the condition, and

  
  

• A specific nexus: how the medical condition prevents the applicant from learning or demonstrating knowledge of English and/or civics.

USCIS stresses: a diagnosis alone is not enough. The link between the medical condition and the inability to meet testing requirements must be clearly and convincingly explained.

3. Increased Oversight and Fraud Prevention

USCIS has implemented tighter fraud detection measures after uncovering patterns of abuse.

“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.” — USCIS Policy Alert, June 13, 2025

The agency is now flagging:

• Multiple N-648s filed for a single applicant,

  
  

• Certifications from doctors with high volumes of filings,

  
  

• Incomplete or inconsistent submissions.

  
  

4. New Interpreter and Telehealth Standards

USCIS clarified that any interpreter used during the medical evaluation must be identified on the form. For telehealth evaluations, the exam must follow state laws and medical standards, just like an in-person visit.

Who Is Affected?

These updates most directly affect:

• Seniors or older adults with dementia, Alzheimer’s, or cognitive decline,

  
  

• Applicants recovering from stroke or neurological injury,

  
  

• Individuals with developmental disabilities,

  
  

• People with long-term psychological impairments or mental health conditions.

  
  

For those who truly qualify, the medical exemption remains available, but applicants will need stronger, clearer documentation than before.

What You Should Do Now

If you or a loved one may qualify for the medical exemption, here are five essential steps to take:

1. Consult a licensed doctor or clinical psychologist who understands the N-648 process. The medical professional must be qualified to assess cognitive or physical impairments and be able to explain their impact on learning ability.

   
   

2. Prepare the N-648 form early. Under the new policy, it must be submitted at the same time as the N-400 naturalization application. Delayed submission without a clear explanation could hurt your case.

   
   

3. Include detailed medical records and history. This helps USCIS see the full picture and strengthens the explanation of how the condition prevents English or civics learning.

   
   

4. Avoid submitting multiple N-648 forms unless absolutely necessary. If a second opinion is truly required, make sure to clearly document why and ensure that both forms are consistent.

   
   

5. Consider working with an experienced immigration attorney. The new guidelines are strict, and legal guidance can help avoid delays, rejections, or unintentional mistakes.

   
   

⚠️ Beware of Scams and False Promises

Unfortunately, these tighter rules have also led to an increase in scams targeting naturalization applicants. Some individuals or unscrupulous “consultants” may promise that you can become a U.S. citizen without taking the English and civics tests, regardless of your medical condition. These promises are misleading and simply untrue.

Be cautious of anyone who:

• Guarantees naturalization without properly filing Form N-648,

• Charges large fees for vague or unofficial “medical waivers”

• Suggests submitting multiple N-648 forms to improve chances, or

• Pressures you to sign documents you do not fully understand.

Always work with licensed medical professionals and trusted immigration attorneys. We encourage you to ask questions, seek second opinions, and never rush into decisions.

🧭 Final Thoughts

The goal of these changes, according to USCIS, is to ensure that “the disability exception remains available to those who genuinely need it.” For families supporting aging parents or individuals with real impairments, the door is still open, but the process is more careful and exacting than before.

At Tran Flores Law, we help clients navigate this process with compassion and precision. If you or a loved one is applying for citizenship with a disability or long-term medical condition, we can help make sure your case is properly supported under these new guidelines. 📞 Call us at (512) 894-9984 to schedule a consultation and learn how we can assist.