USCIS Eases Requirements on Naturalization Applicants Needing Disability-Based Waiver of Citizenship Exams

October 19, 2022, U.S. citizenship applicants with a physical or mental disability who need a waiver of the naturalization exam requirements should have an easier time obtaining a sufficiently convincing report from a doctor, under revised U.S. government guidelines.

By , J.D.


Applicants for naturalized U.S. citizenship who need to request a waiver of the English and civics exam requirements due to a physical or developmental disability or mental impairment can do so only by having a doctor fill out Form N-648, Medical Certification for Disability Exceptions. Unfortunately, it's a long and complex form, and many doctors don't understand what information they need to convey in order for the applicant to succeed in convincing U.S. Citizenship and Immigration Services (USCIS) to grant the waiver. Fortunately, USCIS recently issued a shortened and simplified version of the N-648, and announced new policy guidance to go with it.

The main changes include:

  • adding new telehealth exam guidelines, requiring that the medical professional be licensed and follow the respective state telehealth laws and requirements
  • removing redundant questions
  • eliminating questions about how each relevant disability affects specific functions of the applicant's daily life, including the ability to work or go to school
  • eliminating questions about dates of diagnosis, severity of each disability, and whether the certifying medical professional has a pre-existing relationship with the applicant, and
  • allowing applicants to submit Form N-648 after filing their Form N-400, rather than requiring concurrent filing.

The revised N-648 also added something new: a place for the doctor to indicate that the applicant is not capable of understanding the oath of allegiance to the United States, and therefore needs a waiver of taking the oath. Advocates are concerned that doctors will simply check this box along with the rest, however, not realizing that this would require finding an authorized family member or court-appointed surrogate to act entirely on the applicant's behalf during the naturalization application and swearing-in process.

See How the USCIS Interviewer Will Approve or Deny an N-648 Disability Waiver for more information, and Chapter 3 - Medical Disability Exception of the USCIS Policy Manual.

Effective Date: October 19, 2022