Qualifications for an N-648 Medical Exception
to the English/ Civics Test

As you may know, all naturalization applicants are required to take tests in English and civics. 

A naturalization applicant who is looking for an exception to the educational requirements files a Medical Certification for Disability Exceptions through Form N-648​, which is an attachment to the application for naturalization.​ See 8 CFR 312.2(b)(2). The first edition of Form N-648 was made available to the public as an attachment to the final rule. See 62 FR 12915-12928 (March 19, 1997). See 74 Interpreter Releases 512-15 (March 24, 1997). A medical professional who is licensed has to complete the form. This medical professional is required to certify that the medical condition of the applicant prevents him or her from matching the English requirement, the civics requirement, or both of the requirements. ​

​The United States Citizenship and Immigration Service (USCIS) accepts that there are particular circumstances that could prevent the submission of the application for naturalization and the disability exception form does not need to be submitted at the same time but at any time in the naturalization process.​

Asking for an exception to the requirements for the English and civics components is not the same as asking for an accommodation to the examination process for naturalization. ​An exception typically exempts the applicant from meeting the educational requirements totally, while an accommodation just modifies the way in which an applicant may meet the educational requirements; it doesn’t exempt the person from the educational requirements.​

​Reasonable accommodations could include interpreters in sign language, extended testing time and testing that is off-site. A disability exception demands that an applicant provides evidence that his or her medical state stops him or her from ​abiding by​ the English and civics requirements, even after taking into consideration reasonable accommodations. ​

​USCIS only authorizes the following licensed medical professionals to certify the disability exception form:​

• Medical doctors;​
  
  
• Osteopathy doctors and​
  
  
• Clinical psychologists. See 8 CFR 312.2(b)(2).
  
  

These medical professionals have to be licensed so that they can practice in any US state and Washington, D.C., the Virgin Islands, Puerto Rico, Guam or the Commonwealth of the Northern Mariana Islands. Initially, the corresponding Notice of Proposed Rulemaking (NPRM) issued by legacy INS to address this legislation proposed that all exception eligibility determinations be based on individual assessments by civil surgeons or qualified individuals or entities designated by the Attorney General. The proposed rule suggested that the civil surgeon (or “authorized entity”) provide their assessment in a one-page document. The assessment would attest to the origin, nature, and extent of the applicant's medical condition. INS removed the requirement for a civil surgeon determination in the final rule. See NPRM at 61 FR 44227-44230 (August 28, 1996).

The medical professional is required:​

• to medically examine the applicant;​
  
  
• to describe the type of medical condition and its extent on ​Form N-648​;​
  
  
• to describe how the applicants medical state relates to his or hers inability to conform with the requirements of the English and civics;
  
  
• to prove that the applicant’s medical condition has already lasted or is likely last at 12 months or more and​
  
  
• to prove that the reason for the medical condition ​is not to do with the use of illegal drugs.
  
  

The medical professional has to complete the form for disability exception using commonly known terminology which does not require medical training to understand. The medical professional who is responsible for certifying the form can include supporting documents like medical diagnostic records and reports.

​An officer is required to review the form for disability exception to determine if the applicant meets the requirements for the exception. This means the form has to adequately establish that the applicant meets the requirements for the exception; or​ that the​ form does not include the right information that establishes that the applicant meets the requirements for the exception.