N-648 U.S. Immigration Policy Changes

On June 13, 2025, USCIS implemented new policy changes that affect Medical Certification for Disability Exceptions (aka N-648 Forms).

The N-648 form is used by individuals who are applying for U.S. citizenship and are unable to meet the English and civics requirements due to a significant medical condition. It provides a legal pathway for requesting an exception when a physical or developmental disability, or a mental health impairment, prevents an individual from successfully completing the naturalization test.

As mental health professionals, we are often called upon to conduct these evaluations and complete the N-648 to document the applicant’s condition and explain how it qualifies them for the exception.

These new policy updates for this form introduce a host of new requirements such as tighter scrutiny and greater responsibility for us as mental health professionals.

In fact, this policy update places a greater burden on mental health providers than ever before. Submitting a weak or vague N-648 is not just a missed opportunity for the applicant. It could put your license and reputation at risk. 

So the below podcast episode goes over all these new changes.

🎙️ Important Updates to N-648 Forms in U.S. Immigration

⚠️The biggest change to how forms are submitted (if we do this wrong, a client could be denied!)

⚠️What officers and adjudicators are now scrutinizing in reports very closely

⚠️What clinicians are actually responsible for when completing the N-648

⚠️GIANT red flags USCIS is hunting for in forms that – in extreme cases – may force them to report the case to their fraud detection and national security unit

🔊 Listen here:

🎧 Apple Podcasts                 🎧 Spotify                        🎧 Google Podcasts

Expectations are higher. But so is the potential for Impact.

If you're not sure where to start or if you want more guidance on conducting assessments for and filling out N-648 forms, then I've got tools to help you.

📝 Conduct N-648 Assessment Course – Whether you’re brand new and want to add these evaluations to your immigration services, or you want to perfect your approach given the new policy changes, this self-paced course provides exactly what you need to do this work ethically. I walk you through the entire process for Certifications of Disabilities. The course includes practical tips, case studies, sample forms, and all the strategies I've developed over the years of doing this work.