The Immigrant Legal Resource Center (ILRC) opposes the general elimination of money order and check payments for immigration benefit filings. This change was introduced by a USCIS alert on changes to the USCIS Policy Manual on August 29, 2025, to be effective as of October 28, 2025. The new guidance states that all applications filed October 28, 2025, or after must pay by ACH bank account payment, credit or debit card, or pre-paid card. No bank checks, certified checks, personal checks or money orders will be accepted thereafter.

On September 30, 2025, ILRC submitted this comment to USCIS to oppose the proposed changes to the N-648 and request that they be withdrawn. The changes create a series of substantial obstacles for naturalization applicants applying for a disability waiver of the English/civics requirement. The proposed changes create a form more than twice the length (10 pp.) of the current form (just over 4 pp.) that creates an undue burden on applicants and the medical professional who must complete the N-648. It also doubles the burden of time for USCIS adjudicators who must review this form.

The barrier that these changes would pose is prejudicial to eligible waiver applicants. Standards expressed in the revised form are outside any guidance provided by the statute, regulations and USCIS Policy Manual. The form purports to create law and invents barriers to eligibility in areas where no such law has been established by legitimate guidance.

This practice advisory provides information about recently implemented fee increases at USCIS and EOIR. These fee increases are a result of the “One Big Beautiful Bill Act” also known as HR1. This advisory explores what we know and what we still don’t know about the fees, how to pay them, and potential future changes.