USCIS Update: New Policy on Form N-648 Medical Certification for Disability Exceptions

On June 13, 2025, U.S. Citizenship and Immigration Services (USCIS) released an important policy update to the USCIS Policy Manual that directly affects Form N-648, the Medical Certification for Disability Exceptions.

This change is designed to strengthen the naturalization process and help prevent misuse of disability-based medical certifications submitted along with citizenship applications.

Key Highlights of the Policy Update:

• Stricter Review of Submissions: USCIS will more carefully examine all N-648 forms to ensure the validity of disability claims.
• Concurrent Filing Requirement Restored: Form N-648 must now be submitted at the same time as Form N-400, the Application for Naturalization, unless there are extenuating circumstances. This reverts back to the pre-2022 policy.
• Limitations on Multiple Submissions: Filing more than one N-648 could lead to additional scrutiny and raise questions about the applicant’s credibility.
• Stronger Medical Justification Needed: The medical professional completing the form must clearly explain how the applicant’s physical or developmental disability or mental impairment prevents them from fulfilling the English language or civics requirements.
• Clarification on Fraud Review: USCIS outlined how it handles potential fraud, including specific examples of situations where they may question the validity of an N-648.

What This Means for You:

If you or a loved one is planning to apply for U.S. citizenship using Form N-648, it is critical to understand these new requirements. Improper or incomplete submissions may delay or jeopardize your naturalization process. Working with an experienced NYC immigration attorney can help ensure that your documentation is accurate, thorough, and compliant with the latest USCIS standards.

Need Help with Form N-648 or Your Naturalization Application?

The immigration team at Pollack, Pollack, Isaac & DeCicco is here to guide you through every step. We can help determine whether you qualify for the disability exception and ensure your Form N-648 is properly completed and filed with your naturalization application.

• Call us today at (212) 233-8100
• Visit us at ppid.com
• Schedule a consultation now to get expert legal support with your Form N-648 and naturalization case.

At PPID, we are committed to helping every client navigate the immigration system with clarity and confidence. Let us help you move forward, call us now!

About The Author

Conrad E. Pollack

Conrad E. Pollack is the Managing Partner and Director of Immigration at Pollack, Pollack, Isaac & DeCicco, LLP. He graduated Magna Cum Laude from New York University and earned his J.D. from Brooklyn Law School. With over three decades of experience in immigration law, Conrad has helped countless clients achieve their American Dream. Under his leadership, PPID has expanded significantly, opening new offices in Peekskill and Brooklyn, NY. He is a member of the American Immigration Lawyers Association and has been recognized for his professional excellence with numerous awards and distinctions. Education: Magna Cum Laude graduate from New York University; J.D. from Brooklyn Law School. Awards: Recipient of numerous professional excellence awards. Memberships: Active member of the American Immigration Lawyers Association.

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