The N648 Exemption, Is It Right For You?

A big part of becoming a U.S. citizen is taking the two-part citizenship exam. It is a challenging exam that consists of an English requirement and a civics portion. Everyone applying for citizenship must take the exam, but there are two exceptions allowed by the government:

• Persons over 50 years old who have been Legal Permanent Residents for over 20 years.
• Individuals applying for U.S. citizenship who need to request an exception to the English and civics testing requirements for naturalization because of physical or developmental disability or mental impairment. This exception is known as the N648.

What is an N648

An N648 exception is for individuals applying for U.S. citizenship who need to request an exception to the English and civics testing requirements for naturalization because of physical or developmental disability or mental impairment.

It is important to note that an N648 exception is not easy to get, and USCIS makes it very difficult. You will need the following:

• Medical records that document a physical or developmental disability. These records are the most crucial element of preparing an N648. USCIS agents will not consider forms without these documents accompanying the N648 form. You will have to demonstrate you have been examined for the same issue, psych testing (if applicable), imaging reports, etc.
• At least one in-person visit to the doctor certifying the N648 form.
• The signatory agent (the person signing the exam) must be a Medical Doctor (MD), a Doctor of Osteopathic (D.O) medicine, or a clinical psychologist (Ph.D. or PsyD).

Some conditions, such as illiteracy (the inability to read), are not acceptable diagnosis for the N648. 

Let’s look at some case examples:

1. Tran is a 60-year-old woman from Vietnam who has had two strokes. As a result of these strokes, she frequently becomes confused. She gets lost out in public, and her family can’t leave her unsupervised because Tran is a danger to herself. She can no longer read or remember simple instructions. Tran also has had numerous brain scans and doctor visits because her family is concerned about her declining abilities. Tran’s daughter has made copies of all these evaluations. Tran is a candidate for an N648.
2. Luca is a 22-year-old man from Italy with Down Syndrome. While he can read simple sentences, the citizenship test is beyond his educational limits. His parents have documentation from his primary care doctor regarding his special needs. They also have his academic records demonstrating diminished intellectual capacity. Luca is a candidate for an N648.
3. Wahid is a 44-year-old man from Lebanon. He spent much of his life in a refugee camp before coming to the U.S. As a result, he never received an education. Wahid can sign his name but can’t read. Wahid is not a candidate for an N648. As stated earlier, illiteracy is not a qualifying condition on its own. Wahid can request the testing materials to be given orally, with extra time and in Arabic.

For special exceptions, USCIS says, ” Under Section 504 of the Rehabilitation Act of 1973, we provide accommodations or modifications for applicants with physical or mental impairments that make it difficult for them to complete the naturalization process. Applicants are encouraged to list their needs in the space provided on Form N-400, Application for Naturalization.”

1. Julia is a 30 year old woman from Nicaragua. When she was fleeing her home, she was knocked unconscious in a fall into a creek bed. As a result, Julia has severe headaches that impair concentration and cannot prepare for the citizenship test. However, she has never had any doctor visits to address her headaches. At present, Julia is not a candidate for an N648. However, suppose Julia could visit a neurologist and her primary care doctor for the headaches. In that case, she would have the medical records to document her migraines; she might be eligible for the N648.

As you can see from the examples, proving an N648 is challenging. If you meet the criteria for the N648, here are some top tips that can help you with a successful filing.

• A completed N648 form (https://www.uscis.gov/sites/default/files/document/forms/n-648.pdf) signed by the providers listed above who must be licensed in the state you are applying. It also has to be certified in the last 6 months.
• A notebook or folder that you take to your N648 interview contains organized medical records related to your disability exception. It is a good idea to have them organized by specialty, for example, all primary care reports, all neurology reports, etc. Anything that makes it easier for the USCIS agent to approve is recommended. The harder the agent has to work to support your N648, the less likely it will be granted.

How do you find a doctor who offers an N648?

You can search the following ways:

• • Using an Immigration Directory such as the Immigration Psych Eval Directory 
  • A search engine search using terms like “immigration doctor/physician, N648 provider near me”
• USCIS has a listing of doctors approved to conduct citizenship and disability exams. It does not include every provider, but these providers on the website have been trained to fill out the forms appropriately. https://my.uscis.gov/findadoctor

How Much Do N648 Exams Cost?

The fees for filing an N648 are free, but you can expect to pay a range of costs starting at $500.00 and expanding depending on the provider. Unfortunately, this is considered a legal issue (as opposed to a medical issue), so many providers can’t bill your insurance. If this fee is prohibitive, ask the provider if they can accept a payment schedule.