USCIS N-648 Evaluation - Medical Disability Waiver 2025
Urgent USCIS N648 Policy Updated June 13, 2025
The U.S. Citizenship and Immigration Services (USCIS) Policy Alert PA-2025-10, issued and effective as of June 13, 2025, represents a fundamental and immediate shift in the adjudicative philosophy governing Form N-648, Medical Certification for Disability Exceptions.1 This is not a minor procedural update but a deliberate move away from the more accommodative framework established in 2022 towards a significantly more stringent, enforcement-oriented posture. The policy's explicit and repeated emphasis on enhancing "the integrity of the review process," ensuring the "veracity of medical certifications," and the active "identification and prevention of fraud" signals a new era of intensified scrutiny for all N-648 submissions.
The most critical changes mandated by this new policy can be summarized as follows:
Reversion to Mandatory Concurrent Filing: The policy returns to the pre-2022 requirement that Form N-648 must be submitted concurrently with the applicant's Form N-400, Application for Naturalization. This eliminates the flexibility introduced in 2022 that allowed for later submissions.
Intensified Scrutiny of the "Nexus": The guidance "reaffirms" the long-standing requirement that the certifying medical professional must "clearly explain the connection" (the nexus) between the diagnosed disability and the applicant's specific inability to meet the English and civics requirements.1 The context of this reaffirmation, within a policy focused on fraud, indicates that adjudicators will demand a higher standard of proof and more detailed explanation than previously accepted.
Introduction of New Credibility "Red Flags": The policy explicitly states that the concurrent submission of multiple Forms N-648 from different medical professionals "may raise concerns about the credibility of the disability or impairment claim" and could trigger further review..This introduces a new, significant risk for applicants who might seek a second opinion after an initial evaluation.
Comprehensive Revision of Adjudicative Guidance: The policy alert details a complete revision of key sections within the USCIS Policy Manual, particularly those concerning an adjudicator's "Credible Reasons to Doubt the Validity of Form N-648" and the standards for determining if a form is sufficient. This signals a lower institutional tolerance for any ambiguity, error, or perceived insufficiency in the certification.
The overarching strategic implication for a forensic psychology firm is clear: the operational environment has decisively shifted from one of presumed validity to one of inherent skepticism. Every N-648 certification must now be conceptualized, prepared, and documented as if it will undergo a rigorous, quasi-adversarial review. The burden of proof resting on both the naturalization applicant and the certifying professional has been substantially increased, demanding a more robust and defensible evaluation and reporting process.
About Dr. Lisa Long – Nationwide Expert in N-648 Psychological Evaluations
Dr. Lisa Long is a nationally recognized forensic psychologist with extensive experience in immigration-related evaluations, including N-648 medical disability waivers. Her evaluations go beyond checklists — they reflect a deep understanding of how multiple medical, neurological, and psychological factors may interact to impair learning, memory, attention, or communication.
Every N-648 evaluation is conducted by Dr. Lisa Long, a licensed forensic psychologist, expert witness in federal immigration court, and published scholar. In 2025, she co-presented original research at the American Academy of Forensic Sciences (AAFS), serves as an associate editor for the Journal of Psychology & Clinical Psychiatry, and has authored research on developmental, cultural, and social psychology.
Our evaluations are:
Confidential and clinically rigorous
Aligned with USCIS and EOIR evidentiary standards
Delivered via secure telehealth in all states participating in the PSYPACT interstate agreement—currently 42 U.S. states
Complete Our N-648 Intake Form to Receive Your Free Expert Case Review
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Answer:
This form is a critical provision within U.S. immigration law that allows certain applicants for naturalization to request an exemption from the English language and U.S. civics testing requirements.The waiver is intended for individuals who have a "medically determinable physical or developmental disability or mental impairment" that prevents them from being able to learn, retain, or demonstrate the required knowledge. To qualify, the condition must have lasted, or be expected to last, for a continuous period of at least 12 months. It is crucial to understand that the waiver is not for individuals who simply find the tests difficult or who have not had the opportunity for education; it is specifically for those whose medical condition is the direct cause of their inability to meet the educational requirements.
To be valid, Form N-648 must be completed and signed by a licensed medical professional. This includes only medical doctors (M.D.), doctors of osteopathy (D.O.), or clinical psychologists. Other licensed professionals, such as therapists, counselors, or nurse practitioners, are not authorized to certify this form.
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Answer:
The N-648 waiver is designed for individuals who cannot meet the English or civics testing requirements due to a medically documented impairment. That includes a wide range of conditions — not just those affecting memory or learning directly, but any diagnosis that, in combination, significantly interferes with functioning.Examples include:
Neurocognitive conditions: Alzheimer’s disease, Major Neurocognitive Disorder, vascular dementia, Parkinson’s-related cognitive decline
Mental health conditions: PTSD, Major Depressive Disorder, Anxiety Disorders, Bipolar Disorder, Schizophrenia
Developmental or language-based disorders: Autism Spectrum Disorder, Intellectual Disability, aphasia following stroke or TBI
Medical conditions with cognitive effects: Diabetes, thyroid dysfunction, chronic pain, cardiovascular disease
It’s not just about the diagnosis — it’s about how the condition affects your ability to learn, remember, and communicate. That’s why we don’t rely on generic templates. Each case is built around how your specific symptoms impair your functioning, whether that’s language comprehension, attention span, executive function, or memory retrieval.
Even if you’re unsure whether your condition qualifies, we offer a free case review after the intake form so you can get clarity before making any decisions.
📝 Ready to start the process?
👉📎 Complete our request form and we’ll send you everything you need to move forward.
We provide multilingual email support and will answer any questions you have before scheduling. -
Answer:Yes — and you don’t need to leave home.
Form N-648 can only be completed by a licensed medical doctor (M.D.), doctor of osteopathy (D.O.), or clinical psychologist (Ph.D. or Psy.D.). It cannot be completed by a therapist, counselor, or nurse practitioner. USCIS requires that the clinician not only be properly licensed, but also able to clearly explain how your condition affects learning, memory, language, and test-taking ability.
At Dr. Long & Associates, all N-648 evaluations are personally handled by Dr. Lisa Long, Psy.D., a nationally recognized forensic psychologist. Evaluations are conducted via secure telehealth, and we are authorized to serve clients in over 42 U.S. states through the PSYPACT interstate agreement.
Every N-648 evaluation includes:
✅ A USCIS-compliant report prepared by Dr. Long
✅ Review of prior medical records (if available)
✅ A detailed explanation of how your disability affects English and civics testing
👉📎 Request your evaluation here – no payment required to get started:
https://form.jotform.com/DrLisaLong/Nationwide-Evaluation-Request-Form -
🔗 1. Establish a Clear “Nexus” Between Condition and Impairment
USCIS isn’t just looking for a diagnosis — they’re looking for a direct and well-documented connection between the medical or psychological condition and the applicant’s inability to meet the English and civics test requirements.
The evaluator must clearly state how the condition affects learning, reading, writing, memory, attention, or verbal communication. Generic language or vague terms like “might affect” or “seems to impair” are not accepted.
Use definitive, functional language like:
“The applicant cannot retain or comprehend spoken English due to working memory deficits.”
“Despite support, the applicant has been unable to learn basic civics content due to severe anxiety and executive dysfunction.”
⚖️ 2. Address the Compounding Impact of Multiple Conditions
Many applicants have more than one diagnosis. USCIS will not piece together the cumulative effect — that must be explained clearly in the form.
For example:
A middle-aged applicant with untreated PTSD and moderate hearing loss may appear cognitively intact during a casual conversation. But when placed under pressure, their auditory processing breaks down, hyperarousal hijacks their focus, and they cannot follow multi-step verbal instructions — making naturalization test conditions functionally impossible.
An elderly applicant with early-stage Alzheimer’s disease and well-controlled hypertension may pass basic orientation tasks. But when asked to retain civic concepts over time or distinguish between similar historical facts, they show semantic memory gaps, impaired executive function, and an inability to retrieve information — especially when fatigue or medication side effects are present.
A young adult with bipolar II disorder and a trauma-related dissociative history may present as superficially competent. But when asked to concentrate, their mind “checks out,” and they’re unable to maintain the sustained attention necessary for structured learning, even in their native language — let alone in English.Make sure the form (and any accompanying report) addresses how the combination of conditions impacts function, not just listing them side by side.
An applicant with a lifelong seizure disorder may appear superficially intact — they’re oriented, conversational, and socially appropriate. But over time, the effects of chronic seizure activity, compounded by years of antiseizure medication, result in slowed processing, word-finding difficulty, and impaired short-term memory.
Medications like carbamazepine, clonazepam, or ethosuximide, while necessary to control seizures, are known to reduce mental sharpness, dull attention, and diminish verbal fluency. Family may report the applicant is “slipping” cognitively — forgetting names, repeating questions, or struggling to follow new instructions.
The dilemma? The medication can’t be stopped, and the cognitive impact is no longer subtle. But because the applicant remains socially appropriate and appears “fine,” the impairment is routinely underestimated or dismissed — especially if the evaluator doesn’t understand the cumulative effects of long-term treatment.
🔍 3. Be Specific About What the Applicant Cannot Do
The medical professional should state clearly:
What tasks the applicant cannot perform (e.g., reading a simple passage, recalling basic facts, answering questions aloud)
Why those tasks are functionally impossible
That these impairments persist despite any support or accommodations
Avoid soft language like:
“The applicant likely has difficulty…”
“It appears that…”
Use statements like:
“The applicant cannot understand or retain simple English vocabulary, even after repeated instruction.”
📄 4. Detail the Evaluation Process and Supporting Documentation
The evaluator should note:
What methods were used to assess the applicant
Whether medical records, past evaluations, or family reports were reviewed
That the impairment is expected to last at least 12 months
Avoid assuming the diagnosis “speaks for itself” — USCIS needs functional explanation, not clinical assumptions.
📚 5. Use Plain Language Complete Every Section
Every section of Form N-648 must be completed thoroughly, using clear, non-technical language. Avoid abbreviations, acronyms, or shorthand. USCIS adjudicators are not medical professionals — they need to understand exactly what the condition is and why it affects learning.
🧠 Final Thought:
This form isn’t just a certification — it’s a legal argument. If it doesn’t explain, justify, and document, it likely won’t be approved.
If you’re unsure whether your current provider has submitted a strong form — or you’ve already received a denial or Request for Evidence (RFE) — we can help.
👉📎 Complete our intake form and we’ll review your situation before you commit to anything.
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Answer:
A denial under the new rules is a very serious matter. Because of the new "red flag" for multiple submissions, simply getting a new N-648 from a different doctor is now a risky strategy that could damage your credibility with USCIS. Your first step should be to obtain the denial notice and any Request for Evidence (RFE) to understand exactly why the form was deemed insufficient. You must then consult with both an experienced immigration attorney and a forensic evaluator who specializes in these complex cases. A re-evaluation will need to be exceptionally thorough to overcome the initial denial and the skepticism it may have created.
There is Still Hope:
First, you're not alone. We see denials all the time — and most of them happen because the original evaluator didn't understand what USCIS actually requires.Here’s what often goes wrong:
The form was completed by a provider with no immigration evaluation experience
The explanations were vague — words like "might,""likely," or "appears" were used
The evaluator didn’t explain the impact of the condition on English/civics testing
The form lacked a clear nexus between the diagnosis and the applicant’s functional limitations
The doctor left off required details or used language that doesn’t meet forensic standards
Unlike clinical or general medical evaluations, N-648 forms must be written for a legal audience. USCIS wants clear, unambiguous statements — such as:
“This applicant cannot, even with accommodations, learn, retain, or demonstrate the required knowledge…”
That kind of statement goes against how most medical professionals are trained to write — which is why many well-meaning doctors get this wrong.
If your form was denied, you may have received a Request for Evidence (RFE) or a notice explaining why it was insufficient. In these cases, we conduct a full re-evaluation, complete a new Form N-648, and often provide an additional brief report to ensure the officer fully understands the basis for the exemption.
👉📎 Complete the intake form and we’ll review your denial notice and help you fix it — even if you already submitted once before.
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The Policy Pendulum: A Comparative Analysis of N-648 Standards (2020-2025)
To fully grasp the magnitude of the changes implemented by PA-2025-10, it is essential to analyze them within the context of the preceding policy shifts. The N-648 standards have swung dramatically over the past five years, moving from a high-burden framework in 2020 to an accommodative one in 2022, and now back to an even more rigorous enforcement model in 2025. This historical context illuminates the agency's rationale and highlights the specific areas where clinicians must now exercise the greatest care.
The Pre-2022 Standard (PA-2020-25): The High-Burden Framework
On December 4, 2020, USCIS issued Policy Alert PA-2020-25, which established a high bar for a "properly completed" Form N-648. This policy was designed to elicit a comprehensive and detailed clinical picture from the certifying professional. Its key provisions mandated that the clinician provide highly specific information, including:
The dates of diagnosis for each condition and the date the impairment itself began.
A detailed description of the severity of each disability or impairment cited on the form.
A specific description of how each relevant disability or impairment functionally affected the applicant's daily life.
This framework demanded a granular, functional analysis from the clinician. It was not enough to simply state a diagnosis; the professional was required to document the condition's history, its severity, and its tangible, real-world impact on the applicant. This placed a significant documentation burden on the evaluator to construct a complete and compelling narrative of impairment.
The 2022 Easing of Requirements (PA-2022-25): The Accommodative Interlude
In response to public feedback and stakeholder concerns that the 2020 policy was overly burdensome and created an atmosphere of "suspicion of fraud," USCIS issued Policy Alert PA-2022-25 on October 19, 2022. This policy represented a significant relaxation of the N-648 standards and is the immediate "prior state" against which the 2025 changes must be measured.
The most notable changes in the 2022 policy were the explicit elimination of questions and requirements that had been central to the 2020 framework. Under this policy, USCIS removed the need for clinicians to provide :
Dates of diagnosis and when the impairment began.
A description of the severity of the disability.
A description of the effects on the applicant's daily life.
Information regarding the history of the doctor-patient relationship.
In addition to removing these documentary burdens, the 2022 policy introduced significant procedural flexibility. It explicitly permitted the submission of Form N-648 after the initial Form N-400 had been filed, providing a safety net for applicants who discovered the extent of their difficulties only upon attempting the naturalization interview. It also provided the first formal policy guidance accepting telehealth examinations for N-648 purposes. This 2022 policy was characterized by reduced documentary requirements, increased procedural flexibility, and an official effort to lessen the burden on both applicants and clinicians.
The 2025 Reversion and Enhancement (PA-2025-10): A Return to Rigor
The June 13, 2025 policy alert is a forceful and unambiguous reversal of the 2022 accommodative stance. It not only "returns to the prior policy (pre-2022) of requiring aliens... to submit Form N-648 concurrently" but also enhances the overall level of scrutiny beyond that seen even in the 2020 framework.
The agency's oscillating priorities between stakeholder accommodation and fraud prevention drive this policy pendulum. The 2022 alert directly cited "public's feedback" and reducing "burdens" as the impetus for its changes. In stark contrast, the 2025 alert repeatedly cites the need to combat "fraud," ensure "veracity," and enhance "integrity" as its core purpose. This juxtaposition reveals the agency's perception that the 2022 accommodations created an unacceptable level of risk and vulnerability to fraud, thereby necessitating a sharp and decisive correction.
While PA-2025-10 does not explicitly reinstate the specific questions from the 2020 version of the form, its intense focus on a "clearly explain[ed] connection" and the "veracity of medical certifications" functionally resurrects the
need for the same level of detailed evidence. Adjudicators are now being directed to demand the substantive proof of severity and functional impact that the 2020 form questions were designed to elicit. Furthermore, the 2025 policy introduces new enforcement mechanisms and red flags, such as scrutiny of multiple filings, that were not present in either of the prior policy iterations, creating a more challenging adjudicative climate than ever before.
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Only a licensed medical doctor (M.D.), doctor of osteopathy (D.O.), or a licensed clinical psychologist (Ph.D. or Psy.D.) is authorized to complete and certify Form N-648. Therapists, counselors, social workers, and other allied professionals are not qualified under USCIS guidelines to sign this form.
In addition to meeting the licensing requirement, it is strongly recommended that the provider have specific forensic expertise in conducting N-648 evaluations. The standards for approval have become more stringent, and the documentation now demands a high degree of legal and clinical precision. A well-intentioned family doctor may not be familiar with these evolving evidentiary expectations, which can result in an incomplete or non-compliant submission—potentially leading to denial.
Moreover, USCIS policy guidance now explicitly links N-648 adjudication to Executive Order 14148 and Executive Order 14159—the latter entitled “Protecting the American People Against Invasion.” This shift is not merely symbolic. It reframes the disability waiver not as a matter of routine civil rights or disability accommodation, but as a national security concern. As a result, many general practitioners and primary care physicians have grown increasingly hesitant to complete these forms, particularly when the risk of denial or federal scrutiny is high.
To safeguard your application, we advise obtaining your N-648 from a provider who not only meets the formal credentialing requirement but also understands the quasi-legal documentation standards now expected in this context.
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USCIS has significantly increased scrutiny of Form N-648 submissions. As of Policy Alert PA-2025-10, the agency formally revised the section titled “Credible Reasons to Doubt the Validity of Form N-648” and expanded the list of red flags that may trigger denial—even if the form appears medically reasonable on its face. These red flags are not mere technical errors; they are treated as potential indicators of fraud, malingering, or applicant misconduct. Below are the most critical factors that can lead to rejection:
🔴 1. Multiple N-648 Submissions
Submitting more than one N-648—especially with different clinicians—can be interpreted as “doctor shopping.” The new policy warns adjudicators that this may reflect an attempt to manipulate the process rather than correct deficiencies, undermining the applicant’s overall credibility.
🔴 2. Contradictions with Prior Records
If the N-648 conflicts with other USCIS filings, prior medical records, interview responses, or sworn statements, this raises immediate red flags. Inconsistencies are now interpreted as signs of unreliability or misrepresentation.
🔴 3. Vague or Generic Medical Explanations
USCIS now rejects forms that offer boilerplate text, unsupported diagnoses, or fail to explain how the disability directly prevents the applicant from learning or demonstrating English or civics knowledge. Clinical credibility hinges on specificity, not generalities.
🔴 4. No Longitudinal Medical History
Forms completed without review of prior medical records or based solely on a single encounter—especially one conducted recently—may be deemed medically and legally insufficient. A credible N-648 must reflect a long-standing, well-documented impairment.
🔴 5. Unsupported Claims of Permanence
Marking a disability as “permanent” without clear justification, especially for conditions that are treatable or situational (e.g., depression without treatment history), is seen as an attempt to exaggerate. “Permanent” must mean non-recoverable, with no realistic chance of improvement.
🔴 6. Missing or Implausible Accommodations Section
Every form must indicate whether the applicant could complete the test with reasonable accommodations (e.g., extra time, oral presentation). Failing to address this, or claiming accommodations wouldn't help without explanation, undermines the legitimacy of the impairment.
N 648 Form Guide - Infographic Updated 2025
