ILRC Comment Opposing Revisions to N-648, Medical Certification for Disability Exceptions

Citizenship and Naturalization
Family-Based
Policy Advocacy
U Visa/T Visa/VAWA
Publication Date

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30, 2025, ILRC submitted this comment to USCIS to oppose the proposed changes to the N-648 and request that they be withdrawn.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.

Audience
Practitioners