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СпутникиРНSpaceXРоскосмосNASAILRC Comment Opposing Changes to N-648 Medical Certification for Disability Exceptions Form
Policy Advocacy
cbrown
Tue, 07/07/2026 - 07:50
Publication Date
Jul 07, 2026
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On June 29, 2026, the Immigrant Legal Resource Center (ILRC) submitted comments urging USCIS to withdraw its proposed revisions to Form N-648, the Medical Certification for Disability Exceptions used by naturalization applicants seeking a waiver of the English and civics requirements based on disability. ILRC commented that the proposed revisions unlawfully impose new eligibility standards that are not authorized by the Immigration and Nationality Act, federal regulations, or USCIS's own Policy Manual. The comments explain that the expanded 10-page form would create significant new burdens for applicants and medical professionals by requiring information unrelated to the legal standard for a disability waiver, including preferences for a "regularly treating physician," questions about treatment and daily activities, and an in-person examination requirement that conflicts with existing USCIS telehealth guidance. ILRC adds that the revisions violate the Administrative Procedure Act and the Paperwork Reduction Act by effectively creating new policy through a form revision rather than through lawful rulemaking.
While supporting USCIS's decision to remove the question regarding an applicant's ability to understand the Oath of Allegiance, ILRC urges the agency to withdraw the remaining proposed changes, which would create unnecessary barriers to naturalization for qualified applicants with disabilities.
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ILRC-Comment-on-N-648-Proposed-Changes.pdf
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Practitioners
On June 29, 2026, the Immigrant Legal Resource Center (ILRC) submitted comments urging USCIS to withdraw its proposed revisions to Form N-648, the Medical Certification for Disability Exceptions used by naturalization applicants seeking a waiver of the English and civics requirements based on disability. ILRC commented that the proposed revisions unlawfully impose new eligibility standards that are not authorized by the Immigration and Nationality Act, federal regulations, or USCIS's own Policy Manual. The comments explain that the expanded 10-page form would create significant new burdens for applicants and medical professionals by requiring information unrelated to the legal standard for a disability waiver, including preferences for a "regularly treating physician," questions about treatment and daily activities, and an in-person examination requirement that conflicts with existing USCIS telehealth guidance. ILRC adds that the revisions violate the Administrative Procedure Act and the Paperwork Reduction Act by effectively creating new policy through a form revision rather than through lawful rulemaking.
While supporting USCIS's decision to remove the question regarding an applicant's ability to understand the Oath of Allegiance, ILRC urges the agency to withdraw the remaining proposed changes, which would create unnecessary barriers to naturalization for qualified applicants with disabilities.
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