Medical Certification for Disability Exceptions

OMB No. 1615-0060; Expires 10/31/10

N-648, Medical Certification
for Disability Exceptions

Department of Homeland Security
U.S. Citizenship and Immigration Services

Instructions
What Is the Purpose of This Form?
This form is intended for applicants for U.S. citizenship who
seek an exception to the English and civics testing
requirements for naturalization "because of physical or
developmental disability or mental impairment."

An applicant's difficulty in fulfilling these requirements, such
as illiteracy in his or her native language, is not sufficient by
itself to support a finding of eligibility for the exception.
Additionally, an applicant who can meet the English and
civics requirements with accommodations should not submit
this form. Under the Rehabilitation Act of 1973, USCIS makes
reasonable modifications or accommodations to enable
applicants with disabilities or impairment(s) to participate in
the English and civics testing requirements for naturalization.

DRAFT

What Are the Naturalization Testing
Requirements?

An applicant for naturalization is generally required to
demonstrate:

Knowledge of the English language including an ability to
read, write, and speak words in ordinary usage; and
knowledge and understanding of the fundamentals of the
history, principles, and form of government of the United
States.
To implement these requirements, USCIS administers tests of
each applicant's ability to read, write, and speak English words
in ordinary usage and to answer basic questions about the
government and history of the United States (civics).
However, the law allows an exception to the English and
civics testing required for naturalization in the case of an
applicant who is unable to comply "because of physical or
developmental disability or mental impairment."

Who Should Use This Form?
Applicants for naturalization must submit Form N-648,
Medical Certification for Disability Exceptions, along with a
completed Form N-400, Application for Naturalization, if they
are seeking an exception from the English and civics
requirements. Form N-648 is intended for applicants with
medical condition(s) that are long-term (lasting 12 months or
longer) and so severely debilitating that they are incapable of
meeting the English or civics requirements for naturalization.
USCIS will evaluate the completed Form N-648 to determine
whether the applicant qualifies for an exception from those
requirements.

Who Is Not Eligible?
An applicant for naturalization who is capable of learning or
demonstrating the required knowledge and understanding of
basic English and civics, as explained above, is not eligible for
an exception from the English and civics requirements and
should not submit this form.

Reasonable modifications or accommodations may include
but are not limited to: sign language interpreters, extended
time for testing, or off-site testing. Applicants who believe
that they will need a reasonable modification or
accommodation to take the tests should refer to Part 3.I of the
Step-by-Step Instructions in the General Instructions of Form
N-400.

Who Is Authorized to Complete This Form?
All parts of this form (except for the "Applicant Attestation"
in Part I) must be completed by a currently licensed medical
doctor, doctor of osteopathy, or clinical psychologist (a
"medical professional"). The medical professional must have
professional expertise in diagnosing and evaluating an
applicant for a physical or developmental disability or
impairment that makes the applicant incapable of meeting the
English or civics requirements for naturalization.
An employee under the direct supervision of the certifying
medical professional may, if necessary, fill in the form with
information directly provided or verified by the certifying
medical professional. However, the certifying medical
professional who signs the form under penalty of perjury
remains responsible for the accuracy of its contents.

What Qualifications Must a Certifying
Medical Professional Have?
The licensed medical professional certifying this form must
have training and experience in the field of the applicant's
claimed disability or impairments. A medical professional
who is not a specialist in the field of the claimed disability or
impairments may complete this form only if his or her
training, experience, or other qualifications enable him or her
to make the disability or impairment assessment.

Form N-648 Instructions (Rev. 02/04/09) Y

Because only severe and lasting disabilities are eligible for the
exception to the naturalization testing requirements, the
medical professional who makes the certification should
normally be "the treating physician"; that is, the medical
professional who has been regularly treating the applicant for
the claimed disability or impairment. If the certifying medical
professional is not the applicant's regular treating physician,
the reason for the substitution should be explained in item 4 of
Part II, as well as information regarding the future plan of
treatment for the applicant.

Examples of Insufficient and Sufficient Responses:
The following examples illustrate acceptable and
unacceptable responses regarding diagnosis and nexus
(Items 9 and 10).
The actual medical certification must address the condition of
the individual applicant who has been examined.

DRAFT

What Is Required for a Complete Medical
Certification?

The medical professional completing this form must provide
an accurate assessment of the applicant's disability or
impairment so that USCIS can determine whether the
applicant qualifies for an exception from the English and
civics requirements for naturalization. The medical
professional must provide all of the following:
1. A certification of the duration of the claimed disability or
impairment and whether it is the direct result of the
applicant's illegal use of drugs (Items 7 and 8);
2. A clinical diagnosis and description of the applicant's
claimed disability or impairment, a list of medically
accepted techniques used to reach the diagnosis, and any
applicable DSM-IV-TR code for each mental impairment
(Item 9);
3. A detailed explanation of the nexus (connection) between
the impairment and the applicant's capacity to learn and
demonstrate the required knowledge and understanding of
English and civics. This explanation must include a
description of how the claimed disability or impairment
resulted from an anatomical, physiological, or
psychological abnormality (Item 10); and
4. A certified opinion as to whether the applicant is unable,
even with reasonable accommodations or modifications,
to learn and/or demonstrate the required knowledge of
English or civics because of the documented medical
condition(s) (Items 11 and 12).
If the medical professional does not provide all required
information, USCIS may deem Form N-648 insufficient.
In order to facilitate the adjudication of Form N-648, the
medical professional may also submit copies of relevant
medical diagnostic reports or records to further substantiate
the claim of medical disability indicated on the form.
However, note that a supplemental report is not acceptable as
a substitute for any of the responses required in Part II of this
form.

Example 1:
Insufficient Answer:

Item 9 (Diagnosis): "The patient is a 42-year-old female
who suffers from Angelman syndrome, which is a complex
genetic disorder that affects the nervous system."
Item 10 (Nexus): "The patient is unable to learn a new
language and U.S. history and civics."

(Comment: The doctor failed to articulate how the
impairment is related to the applicant's ability to learn or
demonstrate knowledge of English or civics.)
Sufficient Answer:
Item 9 (Diagnosis): "The patient is a 42-year-old female
who suffers from Angelman syndrome, which is a complex
genetic disorder that affects the nervous system, typically with
developmental delay or mental retardation, severe speech
impairment, seizures, small head size (microcephaly), and
problems with movement and balance (ataxia). The resulting
delayed mental development was first noticed in this patient at
the age of eight months, and she suffered from severe learning
disability since childhood."
Item 10 (Nexus): "The most common cause of Angelman
syndrome is a small deletion (missing piece) of the UBE3A
gene in the maternally inherited chromosome 15, either
through gene mutation or chromosomal change, causing the
person to have no active copies of the gene in the brain.
Because of the chromosomal change and the loss of gene
function in this patient's brain, she is incapable of learning,
remembering, or demonstrating knowledge of English or
civics."
(Comment: The doctor adequately described the effect of the
Angelman syndrome on the patient's cognitive functions and
provided a definitive opinion explaining why as a result of it
the patient is unable to learn and demonstrate knowledge of
English or civics.)

Form N-648 Instructions (Rev. 02/04/09) Y Page 2

Example 2:
Insufficient Response:
Item 9 (Diagnosis): "The patient has Down's Syndrome."
Item 10 (Nexus): "The patient should be exempted from the
English language and U.S. civics requirements for citizenship
due to his medical condition."
(Comment: The doctor failed to explain how the applicant's
condition prevents him from learning or demonstrating
knowledge of English or civics.)
Sufficient Response:

If either the applicant or the medical professional includes in
this form any information that the party knows to be false, that
person may be liable for criminal prosecution under U.S. laws.
In addition to the criminal penalties under Title 18 of the
United States Code, Section 274C of the Immigration and
Nationality Act and 8 U.S.C. 1324c provides for civil
penalties.

General Instructions

DRAFT

Item 9 (Diagnosis): "The patient has Down's Syndrome,
which is a genetic condition that causes delays in physical and
intellectual development. While many individuals with mild to
moderate forms of Down Syndrome are capable of daily tasks
and working in the community, this patient suffers from a
particularly severe form. It was diagnosed in utero through a
Chorionic Villus Sampling (CVS). He has an IQ of 50."
Item 10 (Nexus): "The patient's condition is a global, lifelong
impairment that severely affects cognition, language, and
motor skills. Because of this impairment, his memory is
deficient, he cannot learn new skills, and he is not capable of
reasoning but only of performing simple daily activities. The
patient's severe mental disability makes him incapable of
learning a new language (even basic words) and
demonstrating the required knowledge of U.S. history and
government."
(Comment: The doctor adequately addressed the nexus
(connection) between the condition and how if affects the
applicant's functioning and ability to learn to demonstrate
knowledge of English or civics.)

What Are the Penalties for Making False
Representations?
Both the applicant and the medical professional are required to
attest to the contents of this form under penalty of perjury.
Title 18, United States Code, Section 1546, provides that:
Whoever knowingly makes under oath, or as permitted under
penalty of perjury under Section 1746 of Title 28, United
States Code, knowingly subscribes as true, any false statement
with respect to a material fact in any application, affidavit, or
other document required by the immigration laws or
regulations prescribed thereunder, or knowingly presents any
such application, affidavit, or other document containing any
such false statement, shall be fined in accordance with this
title or imprisoned not more than ten years, or both.

Step 1. Fill Out Form N-648
All parts of this form (except for the "Applicant Attestation"),
must be completed by a licensed medical doctor, doctor of
osteopathy, or clinical psychologist.
Part I of this form must be signed by the applicant or the
applicant's authorized representative.
All questions must be answered fully and accurately. If an
item is not applicable, indicate it with "N/A." If the answer is
none, write "None."
USCIS recommends that the certifying medical
professional complete and print the fillable electronic
Form N-648 provided on the USCIS website
("Immigration Forms" link, www.uscis.gov). Note that if
you need additional space to complete the answer to any item,
the information fields in the fillable electronic form will
expand to accommodate the additional information.
If the application is prepared manually, print or type legibly
in black ink. If additional space is needed to complete the
answer to any item, the certifying medical professional may
attach an additional sheet of paper indicating the item
number to which the attachment refers.
Note that each additional page or supplementary attachment
to the completed form, including medical report(s), must
include the name and Alien Registration Number (ANumber) of the applicant and the complete name and
signature of the medical professional.
After the medical professional has completed the form
electronically or manually, he or she must provide it to the
applicant.

Step 2. The Applicant Submits the Completed Form
N-648 to USCIS

Form N-648 Instructions (Rev. 02/04/09) Y Page 3

When and Where Should This Form Be
Submitted?
All applicants seeking an exception from the testing
requirements for naturalization should submit to USCIS a
completed Form N-648 as an attachment to the applicant's
Form N-400 at the same time Form N-400 is filed with
USCIS.

USCIS Forms and Information
To order USCIS forms, call our toll-free number at
1-800-870-3676. You can also get USCIS forms and
information on immigration laws, regulations, and procedures
by telephoning our National Customer Service Center at
1-800-375-5283 or visiting our Internet website at
www.uscis.gov.

DRAFT

USCIS recognizes that there may be exceptional
circumstances that do not make it possible for the completed
Form N-648 to be attached to Form N-400 when it is filed
with USCIS. In such cases, the completed Form N-648 must
be submitted to USCIS at the time of the applicant's
naturalization interview. Note that while USCIS will accept
delayed submissions, such claims may delay the adjudication
of the naturalization application.

Privacy Act Notice
Authority for the collection of the information requested on this
form is contained in 8 U.S.C. 1182(a)(15), 1183A, 1184(a),
and 1258. USCIS will use the information principally to
support an individual's application for naturalization.
Submission of the information is voluntary. However, failure
to provide the necessary information may result in the denial of
a request for a waiver of the English language and U.S. history
and civics requirement in the applicant's naturalization
application. USCIS may also, as a matter of routine use,
disclose the information contained on this form to other
Federal, State, local, and foreign law enforcement and
regulatory agencies.

As an alternative to waiting in line for assistance at your local
USCIS office, you can now schedule an appointment through
our Internet-based system, InfoPass. To access the system,
visit our website. Use the InfoPass appointment scheduler and
follow the screen prompts to set up your appointment.
InfoPass generates an electronic appointment notice that
appears on the screen.

Paperwork Reduction Act
An agency may not conduct or sponsor an information
collection and a person is not required to respond to a
collection of information unless it displays a currently valid
OMB control number. The public reporting burden for this
collection of information is estimated at 120 minutes per
response, including the time for reviewing instructions and
completing and submitting the form. Send comments
regarding this burden estimate or any other aspect of this
collection of information, including suggestions for reducing
this burden, to: U.S. Citizenship and Immigration Services,
Regulatory Management Division, 111 Massachusetts
Avenue, N.W., 3rd Floor, Suite 3008, Washington, DC
20529-2210. OMB No. 1615-0060. Do not mail your
application to this address.

Form N-648 Instructions (Rev. 02/04/09) Y Page 4