To request a disability waiver of the U.S. citizenship test, an applicant for naturalization must submit Form N-648, issued by U.S. Citizenship and Immigration Services (USCIS). But Form N-648 can only be completed by U.S. licensed medical doctor, doctor of osteopathy, or clinical psychologist.
Unfortunately, not all doctors are attuned to the complexities of this form, and don't realize that their signature alone is not enough to cause USCIS to approve the disability waiver. So, assuming that you are a friend or relation of the applicant, you will have to work with the applicant's doctor to make sure that the Form N-648 is properly completed.
Which Doctor You Should Ask to Complete Form N-648
The first decision that you and your relative will have to make is which doctor should complete Form N-648. The doctor you select may have a lot, some, or no experience with disability waivers. But the fact that your relative's doctor has never completed Form N-648 is not that important.
What really matters is that the doctor is familiar with your relative's medical condition and history, takes care to fill in the form completely, and provides as much detailed information as possible – without providing unnecessary information that will just cause problems. For example, the doctor is not required to describe how your relative's disability affects your relative's ability to deal with “activities of daily living” such as cooking and cleaning.
Possible Problem: Your Relative Has Not Been Seeing the Doctor For Very Long
Form N-648 contains a section where the doctor must state how long he or she has been seeing your relative. Because the doctor should be familiar with your relative's medical history and condition, the fact that the doctor has been seeing your relative for only a short time could be an issue for the immigration officer who interviews your relative.
To deal with the officer's concerns, your relative's interpreter or attorney should be prepared to explain to the officer how your relative found or was referred to the doctor – and why a doctor who your relative has been seeing for a longer period of time did not complete the form.
The immigration officer just wants to be sure that your relative did not select a doctor who was willing, for the right fee, to lie on Form N-648 to save your relative the trouble of studying for the test.
Why You Shouldn't Ask More Than One Doctor to Prepare a Form N-648
Although it might seem like a good idea, USCIS does not want to see more than one Form N-648 – even if the N-648s are from different doctors. If there is more than one form, the immigration officer will require the applicant to choose one for the officer to review. Some immigration officers might also compare the various Forms N-648 and look for ways in which they are inconsistent.
Of course, asking more than one of your relative's doctors to complete Form N-648 and return it to you is still fine. Then, you or your relative's attorney can review them all and decide which doctor seems to best explain why your relative cannot take the test.
Asking Your Doctor to Provide Detail and Explain the Nexus (Connection)
It is very important that the doctor who prepares Form N-648 for your relative explains in detail how your relative's disability makes him or her unable to take the naturalization test. The key word here is “unable”. That it would be very or even extremely difficult for your relative to study for and take the exam is not enough.
Even if your relative's disability is severe, USCIS will usually reject a medical waiver that includes “conclusory” sentences about the connection between the disability and the applicant's inability to take the naturalization exam.
For example, the officer reviewing Form N-648 would probably reject the waiver request if the doctor writes: “Mrs. Yee cannot take the naturalization exam because she has Alzheimer's dementia.” Such a statement is too conclusory.
By contrast, the following statement would probably be sufficient: “Mrs. Yee cannot take the citizenship exam because she suffers from Alzheimer's dementia, which damages and kills brain cells and therefore has a severe negative effect on cognitive abilities, including comprehension and memory, which are essential to understanding and learning a new language and facts about U.S. history and civics.”
Meet With the Doctor in Person
Because detail is so important on Form N-648, your relative should ask for an individual appointment with the doctor. During the appointment, your relative can describe why he or she believes it impossible to take the naturalization exam. Your relative's doctor can also ask relevant questions and schedule or conduct tests to determine whether your relative qualifies for a waiver.
At the appointment, your relative should also ask the doctor whether he or she thinks that your relative qualifies for a full or partial waiver of the naturalization test. (See the articles under "Waivers for Age or Disability When Applying for Citizenship" for detailed information about how the N-648 is reviewed, including partial and full waivers).
If the doctor suggests that your relative qualifies for only a partial waiver, ask why. The doctor's answer to this question is important because USCIS will be wondering the same thing: How can your relative pass part(s) of the test, but not others? Then ask the doctor to include in Form N-648 information about the medical reasons why your relative can take some parts of the exam, but not others. If the doctor's explanation does not make sense, or you and your relative disagree with the idea of requesting a partial waiver, get a second opinion from another doctor.
Review Form N-648 Before Giving It to USCIS
Although doctors are usually very professional and responsible, they can and do make mistakes. Therefore, it is not enough to simply give your doctor a blank Form N-648 and then pass that form on to USCIS without reviewing it. Instead, you or your relative's attorney must carefully review the filled-in form for completeness and accuracy. Also make sure that your doctor used the current edition of the form. If your doctor used an earlier version, check www.uscis.gov/forms to make sure that it will still be accepted.
If anything seems wrong on the form, do not be afraid to talk to the doctor about it. Although it may seem like a lot of work and you may want to help your relative apply for naturalization as soon as possible, getting the form right the first time will save time in the long run. See "How the USCIS Interviewer Will Approve or Deny an N-648 Disability Waiver" for more on this process.
Finally, it is never a good idea to ask a doctor to lie or exaggerate on a Form N-648. Everything on Form N-648 should be complete, accurate, and true. If USCIS finds out that your relative was lying about his or her relationship with the doctor or ability to take the naturalization test, your relative might have his or her naturalization application denied or have her naturalization taken away after he or she has already become a U.S. citizen.