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N 648 Citizenship Application. For some immigrants, the biggest barrier to U.S. citizenship is not motivation or good moral character—it is a serious, long term medical condition that makes it impossible to learn or demonstrate English and civics. Form N 648, Medical Certification for Disability Exceptions, exists specifically for those applicants. It allows certain people with qualifying physical, developmental, or mental impairments to request an exception to the English and/or civics testing requirements in the naturalization process.
The sections below explain, in plain language, who qualifies for this exception, how the N 648 fits into the citizenship process, what changed in recent USCIS guidance through 2025–2026, and why working with an experienced clinician—such as a licensed clinical social worker or psychologist who understands immigration evaluations—can be critical to success.
What Is Form N 648 and Who Is It For? What does the medical disability exception actually do? Form N 648 is a USCIS form completed by a licensed medical professional that certifies an applicant is unable to meet the English and/or civics requirements for naturalization because of a qualifying disability. When properly approved, it can:
Waive the requirement to read, write, and speak basic English. Waive the civics test, or in some cases just the English component, depending on the impact of the disability. Allow the naturalization interview to be conducted in the applicant’s native language, with an interpreter if needed.
It is designed for applicants who:
Have a physical, developmental, or mental impairment that has lasted or is expected to last at least 12 months, and Cannot learn or demonstrate English and/or U.S. history and civics even with reasonable accommodations.
Illiteracy alone, lack of education, or nervousness about testing do not qualify for this exception; there must be a documented, clinically supported impairment.
How Does the N 648 Fit Into the Citizenship (N 400) Process? When and how is it filed? Under current USCIS guidance, the N 648 is closely tied to the naturalization application (Form N 400):
Normally, the N 648 should be filed together with the N 400. Recent revisions to the USCIS Policy Manual explain that applicants “must submit” the initial N 648 as a concurrent attachment with the N 400. Late filed N 648s are now treated more strictly. USCIS may accept a Form N 648 filed after the N 400 only in limited “extenuating circumstances,” such as delayed diagnosis, recent significant worsening of a condition, or practical barriers to obtaining an evaluation earlier. Officers have more discretion to treat late submissions as “insufficient” if the explanation is vague or suggests the disability clearly existed before filing but was not documented. The N 648 is reviewed at or before the naturalization interview. The officer examines the form, the applicant’s testimony, and the rest of the A file to determine whether the disability exception is established by a preponderance of the evidence. If the N 648 is approved, the officer should waive the applicable tests and may complete the interview through an interpreter.
If USCIS finds the N 648 insufficient and the applicant cannot pass the English/civics tests, the naturalization application can be denied—though the applicant may reapply or submit a corrected N 648 in a new case.
Who Can Complete Form N 648, and What Must They Include? Why does the choice of clinician matter so much? USCIS authorizes only certain licensed professionals to certify Form N 648:
Medical doctors (MD or DO) Clinical psychologists In some guidance, certain other licensed medical professionals as defined by statute and regulation
These professionals must:
Conduct a face to face clinical examination of the applicant (proposed 2025–2026 changes emphasize in person exams and discourage one time, superficial encounters). Identify and clearly describe each physical, developmental, or mental impairment relevant to the request. Provide a clinical diagnosis, including DSM 5 and/or ICD 10 codes where applicable, linking each diagnosis to functional limitations. Explain how each impairment prevents the applicant from learning or demonstrating English and/or civics, with enough detail that a non medical officer can understand the connection. State that the impairment has lasted or is expected to last at least 12 months, and that it is not primarily due to illegal drug use under the current or proposed rules. Describe the clinical methods used (interviews, neuropsychological testing, record review) and provide the date of last examination.
USCIS policy also now warns against N 648s that rely on no longitudinal history, no review of prior records, or vague claims of “permanence” without evidence. A thorough evaluation with records, collateral information, and clear functional descriptions is far more likely to be accepted.
Licensed clinicians with immigration evaluation experience—such as social work clinicians collaborating with physicians or psychologists—often help ensure that the narrative is both clinically accurate and responsive to USCIS expectations.
What Has Changed in USCIS N 648 Policy Heading Into 2026? How do the 2024–2025 updates affect applicants? Several developments are important for anyone considering an N 648 in 2026:
Stricter expectations around timing and “late” filings. As noted, USCIS now treats N 648s filed after the N 400 as “late” and only accepts them when detailed, credible extenuating circumstances exist. Vague explanations may lead officers to question the validity of the waiver request. More detailed scrutiny of the medical explanation. Officers are directed to look for: A clear clinical diagnosis and code. Concrete descriptions of daily life limitations and how they affect learning or test performance. Documentation that the impairment is long standing and well documented, not based solely on a single brief visit. Proposed form revisions adding more questions. A 2025 notice of proposed changes suggests adding questions about prescribed treatment, daily activities, employment limitations, and drug related impairments, and requiring in person exams. These changes, if finalized, would make superficial or boilerplate N 648s even more likely to be denied. Totality of the evidence review remains key. The Policy Manual now emphasizes that officers must review the entire record, not just isolated answers, and may still approve a request that has some incomplete responses if the overall evidence clearly supports eligibility.
These shifts underscore the need for careful preparation, detailed documentation, and qualified professional support.
How Can a Mental Health Professional Like Claudia Ribas, LCSW, Help? What role can a clinician play in strengthening an N 648? A licensed clinical social worker who specializes in immigration related evaluations brings several strengths to the N 648 process:
Trauma and culture informed assessment. Many applicants seeking disability exceptions have complex histories—war trauma, persecution, chronic mental illness, or developmental issues that were never formally documented in their home countries. A clinician trained in cross cultural mental health can help elicit and frame these histories in a way that is accurate, respectful, and relevant for USCIS. Detailed functional descriptions, not just labels. USCIS cares less about a diagnosis name and more about how symptoms affect memory, concentration, language acquisition, and test performance. A skilled evaluator bridges clinical language and practical examples (“cannot retain new information beyond a few minutes,” “becomes disoriented outside familiar routines,” “severe anxiety prevents participation in structured testing”). Collaboration with attorneys and medical doctors. Many applicants work with immigration attorneys or accredited representatives. An LCSW experienced in this work often coordinates with counsel and treating physicians or psychologists to ensure the N 648 and supporting reports are consistent, comprehensive, and strategically timed with the N 400 filing. Preparation for the interview experience. While clinicians do not coach applicants to “perform,” they can explain how the process works, what kinds of questions USCIS may ask about daily functioning, and how to answer honestly without minimizing or exaggerating symptoms.
Clinicians like Claudia Ribas typically offer these services as part of a broader practice focused on immigrant psychological evaluations for asylum, hardship, VAWA, U visa, and naturalization cases, grounding their reports in both mental health standards and immigration needs.
Earlier Information About N 648 and Citizenship That Still Applies in 2026 The original blog post on Form N 648 and citizenship applications emphasized several points that remain accurate and crucial for applicants today:
N 648 is for serious, documented disabilities—not for avoiding English or civics. The form is intended for applicants who genuinely cannot meet the testing requirements even with reasonable accommodations, due to long term physical, developmental, or mental impairments. Concurrent filing with the N 400 is best practice. The initial guidance that applicants should submit Form N 648 at the same time as their N 400 remains correct and has now been strengthened in USCIS policy language. The medical professional’s opinion is central—but must be well supported. USCIS relies heavily on the certifying clinician’s detailed explanation. Forms that are incomplete, inconsistent with other records, or too vague about functional impact are much more likely to be questioned or denied. Applicants may still request reasonable accommodations in addition to, or instead of, an N 648. For some people, extra time, interpreters, or other accommodations may be enough; for others, a disability exception is necessary. Earlier advice to explore both options with legal and medical professionals remains sound.
For immigrants whose health makes traditional citizenship testing impossible, Form N 648 can be a lifeline. In 2026, the best path forward is clear: consult with a knowledgeable immigration attorney, work with an experienced medical or mental health professional who understands USCIS standards, file the N 648 with your N 400 whenever possible, and ensure that your disability story is documented in full, clinical detail.
The Hecht Ribas Group in Charlotte, North Carolina offers a comprehensive range of psychological services with a focus on individual, couples, and family therapy. They provide support for a variety of issues including relationship difficulties, anxiety, depression, identity and sexual orientation issues. They also offer specialized services such as adoption counseling, family building support (including evaluations for adoption, surrogacy, and donor requirements), and immigration evaluations. With a commitment to providing a safe and non-judgmental space, the Hecht Ribas Group aims to help clients heal, build resilience, and achieve personal growth.