Chapter 3 - Medical Certification for Disability Exceptions (Form N-648)

A. Purpose

U.S. law provides an exception for aliens who are unable to meet the required proficiency in English or the knowledge and understanding of the fundamentals of the history, and of the principles and form of government, of the United States (“civics”) for naturalization because of a physical disability, developmental disability, or mental impairment.^[1]

This medical disability exception to the English and civics requirements for naturalization ensures that aliens with legitimate and demonstrated physical or mental disabilities or impairments are not excluded from the naturalization process.

B. Background

In 1994, Congress enacted legislation providing an exception to the English and civics requirements for aliens filing for naturalization who cannot meet the requirements^[2] because of a physical or developmental disability or mental impairment.^[3]

The English and civics requirements do not apply to aliens filing for naturalization who are unable to comply due to a “medically determinable” physical or developmental disability or mental impairment^[4] that has lasted, or is expected to last, at least 12 months. The regulations define medically determinable as an impairment that results from abnormalities which can be shown by medically acceptable clinical or laboratory diagnostic techniques.^[5]

The alien must demonstrate that he or she has a disability or impairment that affects functioning such that the alien is unable to meet the English and civics requirements for naturalization, even with reasonable accommodations.

A licensed medical professional^[6] must complete a Medical Certification for Disability Exceptions (Form N-648) and certify, under penalty of perjury, that the alien’s disability or impairment prevents the alien from meeting the English requirement, the civics requirement, or both requirements.

C. Submission of Form N-648

1. Form N-648 Submitted Concurrently with Form N-400

An alien seeking an exception to the English or civics requirements or both must submit an initial Form N-648 as an attachment to the Application for Naturalization (Form N-400).^[7] However, USCIS may accept an initial Form N-648 submitted after filing Form N-400, or the submission of multiple Forms N-648, in limited circumstances as set forth below. Aliens should use the form edition of the Form N-648 listed on the form webpage.

2. Late Submissions

A late submission occurs when an alien submits Form N-648 for the first time after filing Form N-400 (including at the interview). However, USCIS may accept late submissions of Form N-648 if the alien demonstrates extenuating circumstances. Aliens may provide supporting evidence and explain the extenuating circumstances that prevented the timely submission of Form N-648 in writing (submitted before or during the interview) or verbally at the interview.

For example, if an alien develops a disability or impairment after filing Form N-400 and provides evidence to support this claim, this change in his or her medical condition would ordinarily constitute extenuating circumstances that justify submitting Form N-648 late. Similarly, if an alien had a medical condition before filing, but it subsequently worsened and the alien is then unable to meet the educational requirement, the alien may be able to establish extenuating circumstances for the late submission. If there are other reasons for submitting Form N-648 late, USCIS evaluates these situations individually to determine whether to accept the late submission.^[8]

Officers should evaluate each form submitted late individually, considering both verbal statements and any supporting documentation. If the explanation to support the late submission is vague, incomplete, or if there is evidence suggesting that disability or impairment existed before filing Form N-400, officers may question^[9] the validity of the medical certification.

Submission of updated or additional Forms N-648 in response to a request from USCIS will not be considered a late submission.

When an alien has already submitted one Form N-648 with his or her Form N-400 but presents a new or updated Form N-648 at the interview, this is considered a multiple submission rather than a late submission.

3. Multiple Submissions

Only one initial Form N-648 should be submitted with the naturalization application. If the alien submits more than one Form N-648 at any stage of the naturalization process—whether during the initial interview, re-examination, or while the application is still pending—the officer may question the validity of the submissions.^[10] The officer should ask the alien to explain why multiple forms were submitted and carefully examine any discrepancies between them.

When two different Form N-648 submissions come from separate medical professionals, this may raise concerns about the credibility of the medical certification, if there are significant inconsistencies in medical assessments or diagnoses. For example, discrepancies regarding the nature or origin of the disability or impairment or its impact on the alien’s ability to meet English or civics requirements may call the validity of the medical certification into question.

If significant discrepancies or inconsistencies exist, the officer may determine that Form N-648 is insufficient. However, before making this determination, the officer must give the alien an opportunity to explain the discrepancies.^[11]

Submission by the alien of a second Form N-648 at re-exam by the same medical professional, or a different medical professional when USCIS has directed the alien to submit a Form N-648 from a different medical professional, to address the insufficiencies USCIS identified in the initial N-648 will not be considered submitting multiple Forms N-648. However, the officer at re-exam should carefully examine the new Form N-648 to ensure that it addresses all insufficiencies and is consistent with the prior Form N-648.

If legitimate concerns about the validity of the medical certification still exist, USCIS may find the Form N-648 insufficient^[12] and require the alien to submit a Form N-648 from a different medical professional.^[13]

D. Distinction Between Medical Disability Exception and Accommodation

Requesting an exception to the English or civics requirements or both is different from requesting an accommodation for the naturalization test or interview.^[14] An accommodation simply modifies the manner in which an applicant meets the educational requirements; it does not exempt the applicant from the English or civics requirements. Form N-648 is not used to request an accommodation.

Reasonable accommodations may include, but are not limited to, sign language interpreters, extended time for completing the English and civics requirements, and completing the English and civics requirements and naturalization interview at an off-site location. A disability exception, which can only be requested by submitting Form N-648, requires an applicant to show that the applicant’s physical or developmental disability or mental impairment prevents the applicant from complying with the English or civics requirements or both, even with reasonable accommodations. The impact of a particular physical or developmental disability or mental impairment may vary between applicants.

It may be possible for USCIS to accommodate one applicant who is affected by a particular physical or developmental disability or mental impairment, while another applicant affected by the same disability or impairment may be eligible for a disability exception.^[15] For example, an applicant who has a traumatic brain injury may require the accommodation of more time to complete the writing portion of the English test, while an applicant with the same diagnosis may not be able to write a simple sentence in English even with an accommodation, and needs to submit a Form N-648.

An applicant may request both a medical disability exception and a reasonable accommodation where both are needed. For example, if an applicant is deaf and uses a sign language interpreter and is also unable to meet the English and civics requirements due to a physical or developmental disability or mental impairment, the applicant may submit a Form N-648 and also request that USCIS provide a sign language interpreter for the naturalization interview.^[16]

E. Authorized Medical Professionals

USCIS only authorizes the following licensed medical professionals to certify the disability exception form:

• Medical doctors;
• Doctors of osteopathy; and
• Clinical psychologists.^[17]

These medical professionals must be licensed to practice in any state of the United States, the District of Columbia, Puerto Rico, Guam, the Virgin Islands of the United States, or the Commonwealth of the Northern Mariana Islands.

F. Scope of Medical Examination

In order for USCIS to consider a Form N-648 sufficient, the medical professional must, at a minimum:

• Conduct an examination of the alien;
• Identify and describe each disability or impairment that affects the alien’s ability to meet the English or civics requirements on Form N-648;
• Explain how each disability or impairment prevents the alien from learning or demonstrating knowledge of English, civics, or both;
• Attest that the disability or impairment has lasted or is expected to last at least 12 months; and
• Attest that the cause of the disability or impairment is not related to the illegal use of drugs.

The medical professional should complete the Form N-648 using common terminology that a person without medical training can understand. While staff associated with the medical professional may assist in completing the form, the medical professional alone is responsible for providing the necessary information, answering the questions, and verifying and attesting to the accuracy of the form’s content. If information is missing from the Form N-648, the officer should review any extra documents provided by the medical professional to determine if the information completes the Form N-648. If the missing information is not present on the additional documentation, the officer must reject the Form N-648 as insufficient.

The medical professional certifying the form may choose to provide additional information as attachments to the Form N-648 to support the claim of disability. Any supporting documentation should be relevant, probative, and credible to establish that the medical disability or impairment prevents the alien from completing the English and civics requirements.

Telehealth Examination

USCIS may accept a Form N-648 certified by an authorized medical professional who completed the alien’s medical examination through a telehealth examination.^[18] The medical professional must be licensed. In conducting telehealth examinations, medical professionals must adhere to the respective state telehealth laws and requirements, otherwise USCIS may request a new Form N-648. After a telehealth examination, the alien should ensure all signatures are present and then submit the Form N-648 to USCIS.

G. Review of Medical Certification

1. General Review Guidelines

The officer must carefully review the form for sufficiency^[19] to determine whether the alien is eligible for the exception. The tables below provide general guidelines on what steps the officer should and should not take when reviewing the Form N-648. The alien has the burden of proof by the “preponderance of the evidence” standard.^[20] The form must be reviewed based on the totality of evidence in the record to assess eligibility.

If USCIS identifies deficiencies in a Form N-648, the alien must submit a new Form N-648.

When reviewing the form, the officer must:

• Determine whether the form has been completed, certified, and signed by all appropriate parties.
• Ensure that the Form N-648 relates to the alien and that there are no significant discrepancies between the form and other available information, including biographic data, testimony during the interview, or information contained in the alien’s A-file or record.
• Determine whether the alien has met his or her burden to establish eligibility for the exception by a preponderance of the evidence. This determination includes ensuring that the medical professional’s explanation is both sufficiently detailed as well as specific to the alien and to the alien’s stated disability or impairment (rather than a generic, “one size fits all” explanation).

When reviewing the form, the officer should not:

• Attempt to determine the validity of the medical diagnosis or second guess why this diagnosis precludes the alien from complying with the English requirement, civics requirement, or both requirements.
• Request to see an alien’s medical or prescription records solely to question whether there was a proper basis for the medical professional’s diagnosis unless evidence exists that creates significant discrepancies that those records can help resolve. The officer may ask follow-up questions to resolve any outstanding issues.
• Require that an alien undergo specific medical, clinical, or laboratory diagnostic techniques, tests, or methods.
• Conclude that the alien has failed to meet the burden of proof solely because the alien did not previously disclose the alleged medical condition in other immigration-related medical examinations or documents. It is appropriate, however, to consider this as a factor when determining the sufficiency of the Form N-648. The officer should always carefully examine the evidence of record and ask follow-up questions to resolve any outstanding issues.
• Refer an alien to another medical professional solely because the alien sought care from a professional who shares the same language, culture, ethnicity, or nationality.

2. Connection Between Medical Disability and Educational Requirements

When reviewing the request for the medical disability exception, the officer must determine whether the medical professional has sufficiently explained with enough supporting details that the alien has a disability or impairment. The medical professional must also explain how the disability or impairment prevents the alien from being able to demonstrate that he or she meets the English requirement, civics requirement, or both (also known as “nexus”).^[21] The explanation should be sufficiently detailed and tailored to the individual alien’s diagnosed disabilities or impairments.

After review of the record, the officer may only grant an exception from the English or civics requirements if the alien has demonstrated by a preponderance of the evidence that the physical or developmental disability or mental impairment results in functioning so impaired as to render the alien unable to:

• Demonstrate an understanding of the English language, including reading, writing, and speaking words in ordinary usage in the English language;
• Demonstrate a knowledge and understanding of the fundamentals of history and of the principles and form of government of the United States; or
• Both. 

3. Use of Interpreters

Certification on Form N-648 and Presence of Interpreter at Medical Examination

A medical professional may use an interpreter during a medical examination. The interpreter must sign the interpreter section of Form N-648. Interpreters who provide services for telehealth medical examinations are not required to complete the interpreter certification on Form N-648. Instead, it is the responsibility of the medical professional to complete the interpreter certification on the form.

When it’s not clear if an interpreter was present during the medical examination, the officer must confirm with the alien whether an interpreter assisted during the medical examination that was conducted to complete Form N-648. For example, the officer may ask the alien how they communicated during the medical examination.

If necessary, the officer may ask the interpreter about the interpretation services he or she provided during the medical examination in connection with the alien’s Form N-648.^[22] Officers may not ask interpreters about the medical condition of the alien. Before questioning the interpreter, the officer must place the interpreter under oath.

If the interpreter who assisted during the medical examination is also serving as the interpreter for the naturalization interview, and is to be questioned as a witness, the interpreter must be disqualified from interpreting for that alien at the naturalization interview unless there is a valid exception for good cause.^[23] If no good cause exception applies, the officer reschedules the interview, as needed, to allow the alien time to find a new interpreter.

Interpreter at Interview

If at the interview the officer needs to ask the alien questions about Form N-648 or explain why it is insufficient, the officer must do so in the alien’s preferred language, with the use of an interpreter,^[24] and while the alien is under oath. If the office has a language service available and the alien agrees, the officer may use the language service when the interpreter provided by the alien is disqualified. In the agency’s discretion, as in all cases, the officer may disqualify an interpreter provided by the alien or a telephonic language service interpreter for cause and reschedule the interview.^[25] If the officer disqualifies the alien’s interpreter and no additional questioning about the Form N-648 is needed to determine its sufficiency, the officer should reject the N-648.

4. Credible Reasons to Doubt the Validity of Form N-648

One of the reasons that USCIS might consider a Form N-648 insufficient is if there are credible reasons to doubt its validity. Such reasons may include, but are not limited to, discrepancies (for example, the medical certification directly conflicts with other evidence), misrepresentation, or fraud. However, USCIS generally presumes that the medical professional’s diagnosis is valid, unless credible evidence suggests otherwise. The presumption that the medical professional has correctly diagnosed the alien’s medical condition is not a presumption that the alien has met his or her burden of establishing eligibility for the waiver.

If an officer identifies inconsistencies or discrepancies in the Form N-648 during the naturalization interview, the alien must be given an opportunity to address the inconsistencies. If discrepancies are not resolved during the interview, the officer may issue a Request for Evidence (RFE). When issuing an RFE, the officer should only request the information necessary to determine the sufficiency of the Form N-648. In some cases, USCIS may require:

• A new Form N-648;
• Medical records to verify the diagnosis; or
• Evidence confirming that the medical professional actually examined and diagnosed the alien.

Such requests are warranted when there are credible reasons to doubt the validity of the Form N-648 particularly if documentary evidence clearly contradicts the medical diagnosis or claimed disability or impairment.

Examples of Credible Reasons to Doubt Validity

The following are examples of situations that may raise credible doubts about the validity of Form N-648, which should guide officers in determining the sufficiency of the form:^[26]

• Lack of Examination or Proper Certification
  • The alien was not examined by the authorized medical professional.
  • The form was certified by someone other than the authorized medical professional.
  • The alien paid for Form N-648 without undergoing a proper medical examination or receiving a diagnosis from an authorized medical professional.
• Fraud or Misconduct by the Medical Professional
  • The certifying medical professional has been or is currently under investigation for immigration fraud, healthcare fraud (such as Medicaid or Medicare fraud), or other fraudulent activities by USCIS Fraud Detection and National Security (FDNS) Directorate, U.S. Immigration and Customs Enforcement, or another federal, state, or local agency.
  • The medical professional has been disciplined by a state medical board for unethical or fraudulent practices.
• Contradictory Information in Alien’s Existing Records
  • Previously submitted Forms N-648 in prior applications or existing medical records in the A-file containing information that directly contradicts the diagnosis or claims made in the submitted Form N-648.
  • Other official documentation contained in the record that directly contradicts the diagnosis or claims made in the submitted Form N-648.
  • The previous petitions and applications such as Form I-693, with medical records that show no history or evidence of the medical condition now claimed in Form N-648.
• Inconsistencies in the Alien’s Interview
  • The alien’s statements during the naturalization interview directly contradict the medical condition or disability described in Form N-648.
• Fraudulent Involvement of Interpreters
  • The interpreter used during the medical examination, the naturalization interview, or both, is known or suspected by FDNS or another state or federal agency to be involved in any immigration fraud, especially fraud related to Form N-648.
• Multiple Inconsistent Forms N-648
  • The alien submits multiple Forms N-648 with conflicting diagnoses or inconsistent information.
• Other Articulable Grounds
  • Any other credible reasons supported by the record that call into question the validity of the form.

Handling Suspected Fraud or Misrepresentation

If any one or more of the above indicators are present, and USCIS suspects or determines that an alien, interpreter, or medical professional has committed fraud or made material misrepresentations in connection with Form N-648, the officer will find the Form N-648 insufficient and refer the case to FDNS for further investigation consistent with appropriate policies and procedures.

5. Requesting Supplemental Form N-648

USCIS may ask an alien to submit a new Form N-648 from a different medical professional when there are doubts about whether the medical professional actually examined and diagnosed the alien, or when the medical certification directly conflicts with other evidence in the record, raising credible concerns about its validity.^[27]

The officer issues an RFE to the alien, clearly explaining all specific reasons for questioning the validity or completeness of the original form. The RFE should include details such as:

• Any inconsistencies observed during the interview that raised credible doubts,
• The alien’s responses to interview questions that conflicted with the medical certification, and
• Any relevant sworn statements submitted during the interview that contradict the medical certification.

H. Sufficiency of Form N-648

The Form N-648 must be certified by the certifying medical professional no more than 180 days before the alien files the naturalization application. Once this requirement is satisfied, the Form N-648 remains valid for the entire naturalization process connected to that particular Form N-400.

An officer must find the Form N-648 insufficient if the form lacks any of the required information detailed below.

1. Sufficient Form N-648

A request for a medical disability exception is sufficient if it contains the following information:​

• Clinical diagnosis of the alien’s disabilities or impairments that render the alien unable to meet the English and civics requirements;^[28]
• Indication whether any disability or impairment has lasted, or is expected to last, at least 12 months;
• Statement that the physical or developmental disability or mental impairment is not the result of the illegal use of drugs;
• Description of the clinical or laboratory diagnostic methods used to diagnose each disability or impairment;
• Date that the medical professional last examined the alien for the disability or impairment;
• A sufficient explanation of how the alien’s disability or impairment prevents the alien from meeting the English requirement, the civics requirement, or both requirements (the “nexus”); and
• Form N-648 must be properly completed, certified, and signed by all appropriate parties.

The table below provides the general procedures for cases where an alien qualifies for a medical disability exception. The procedures apply to any phase of the naturalization examination, including the initial examination, re-examination, or hearing on a denial.

USCIS then determines whether the alien meets all other naturalization eligibility requirements.

2. Insufficient Form N-648

A request for a medical disability exception is insufficient if the Form N-648 omits any required information, contains material inconsistencies or discrepancies, or presents fraud indicators that preclude a finding of eligibility under the preponderance of the evidence standard.^[30]

The table below provides the general procedures USCIS follows when the Form N-648 is found to be insufficient. The procedures apply to any phase of the naturalization examination, including the initial examination, re-examination, or hearing on a denial.^[31]

I. Interview, Re-Examination, and Hearing after an Insufficient Form N-648

1. Initial Interview

Passing the English and Civics Requirements

If an alien’s Form N-648 is found to be insufficient, but the alien subsequently meets the English and civics requirements^[32] in the same examination:

• The officer must provide the applicant the opportunity to proceed with the rest of the naturalization interview to determine if the applicant meets the other applicable eligibility requirements.
• The officer should not determine that the applicant engaged in fraud or lacks good moral character for the sole reason that the applicant met the educational requirements after submitting an insufficient Form N-648.
• The officer may question the applicant further, however, on the reasons for submitting the form, and any other relevant factors, if necessary.^[33]

Failing the English and Civics Requirements

If an applicant’s Form N-648 is found to be insufficient, and the applicant fails to meet the English or civics requirements:

• The officer must notify the applicant of the Form N-648 deficiencies in writing by issuing an RFE that specifically addresses the issues with the Form N-648.
• The officer should schedule the applicant to appear for a re-examination for a second opportunity to meet the English or civics requirements or both, between 60 and 90 days after the initial examination. If the applicant requests that the re-examination be rescheduled to a date that is more than 90 days after the initial examination, the applicant must agree in writing to waive the requirement under INA 336 that USCIS must adjudicate the application within 120 days from the initial interview before the applicant may apply to U.S. district court for review of a pending application for naturalization, and instead permit USCIS to adjudicate the application within 120 days from the re-examination before seeking review.^[34]

2. Re-Examination

If new information is received in support of a Form N-648 that USCIS found insufficient at the initial interview, the officer must review the new evidence at the re-examination. In addition, the officer conducting the re-examination should review the original Form N-648 and accompanying evidence for consistency with the new information.

If an applicant submits a Form N-648 for the first time at the re-examination interview, the officer should review the form to determine if it is sufficient.^[35] If the applicant has established eligibility for the disability exception, the officer should continue the naturalization interview and examination, exempting the applicant from the English or civics requirements, or both, as indicated on the Form N-648. If the medical professional indicated on the form that the applicant is unable to comply with the English speaking requirement, the applicant may use an interpreter during the interview and examination.

If an RFE related to an insufficient Form N-648 was issued at the initial interview and the interviewing officer determines that the evidence submitted in response to the RFE is insufficient:

• The officer must explain the reasons for the insufficiency in the applicant’s preferred language verbally during the interview, using an interpreter, if needed. The RFE also needs to have an explanation of the insufficiency;
• The officer must proceed with the re-examination as if the applicant had not submitted a Form N-648;
• The officer must administer any portion of the English and civics tests that the applicant previously failed;
• The officer must not issue another RFE related to any insufficient Form N-648 to provide the applicant another opportunity to submit a Form N-648 or to take the English and civics tests for a third time;
• If the applicant fails any portion of the test or declines to take the test, the officer must deny the naturalization application based on the applicant’s failure to meet the English or civics requirements or both; and
• In the notice to deny the application for naturalization, the officer must provide an explanation for finding the Form N-648 insufficient.

3. Hearing on Denial

An applicant whose naturalization application was denied may file a Request for a Hearing on a Decision in Naturalization Proceedings Under Section 336 (Form N-336) within 30 calendar days of receiving the adverse decision.^[36]

USCIS may conduct a full de novo hearing on a denied naturalization application, including a full review of any previously submitted Form N-648 as well as other information contained in the record.^[37] An applicant may submit additional documentation at the hearing, including a new or initial Form N-648 and relevant medical diagnostic reports, records, or statements. At the hearing, an applicant will only be allowed to submit one Form N-648 and only allowed to attempt to satisfy the educational requirements once.

In addition, the officer also should follow the same procedures in the hearing as provided in this chapter when making a determination that a Form N-648 filed for the first time at the hearing is sufficient or insufficient.

Footnotes

[^ 1] See INA 312(b).

[^ 2] The term “English and civics requirements” refers to demonstrating English language proficiency, which is determined by an ability to read, write, speak, and understand English, as well as knowledge of U.S. history and government, which is determined by a civics test. See Chapter 2, English and Civics Testing, Section A, Educational Requirements [12 USCIS-PM E.2(A)].

[^ 3] See INA 312(b)(1). See Section 108 of the Immigration and Nationality Technical Corrections Act of 1994, Pub. L. 103-416 (PDF), 108 Stat. 4305, 4309 (October 25, 1994) (adding INA 312(b)).

[^ 4] From now on, the phrase “physical or developmental disability or mental impairment” will be referred as “disability or impairment” for simplicity.

[^ 5] See INA 312(b). See 8 CFR 312.1(b)(3) and 8 CFR 312.2(b).

[^ 6] See Section E, Authorized Medical Professionals [12 USCIS-PM E.3(E)].

[^ 7] See 8 CFR 312.2(b)(2). Aliens filing a naturalization application online should upload a scanned copy of the Medical Certification for Disability Exceptions (Form N-648) using their USCIS online account.

[^ 8] In such cases, the officer should consult with a supervisor for guidance.

[^ 9] For more information about credible doubt, see Section G, Review of Medical Certification, Subsection 4, Credible Reasons to Doubt the Validity of Form N-648 [12 USCIS-PM E.3(G)(4)].

[^ 10] Forms from different medical professionals describing different medical conditions may not pose a credibility issue.

[^ 11] For more information about credible doubt, see Section G, Review of Medical Certification, Subsection 4, Credible Reasons to Doubt the Validity of Form N-648 [12 USCIS-PM E.3(G)(4)].

[^ 12] For more information on what happens when a Form N-648 is found insufficient, see Section H, Sufficiency of Form N-648, Subsection 2, Insufficient Form N-648 [12 USCIS-PM E.3(H)(2)].

[^ 13] For more information on a request for additional disability determination, see Section G, Review of Medical Certification, Subsection 5, Requesting Supplemental Form N-648 [12 USCIS-PM E.3(G)(5)].

[^ 14] See Part C, Accommodations [12 USCIS-PM C].

[^ 15] See the Disability Accommodations for the Public webpage to request an accommodation.

[^ 16] See Part C, Accommodations, Chapter 3, Types of Accommodations [12 USCIS-PM C.3].

[^ 17] See 8 CFR 312.2(b)(2).

[^ 18] See the Why use telehealth? webpage from the U.S. Department of Health and Human Services.

[^ 19] See Section H, Sufficiency of Form N-648 [12 USCIS-PM E.3(H)].

[^ 20] For more information about the preponderance of the evidence standard, see Volume 1, General Policies and Procedures, Part E, Adjudications, Chapter 4, Burden and Standards of Proof [1 USCIS-PM E.4].

[^ 21] See 8 CFR 312.2(b)(2) (“These medical professionals shall be experienced in diagnosing those with physical or mental medically determinable impairments and shall be able to attest to the origin, nature, and extent of the medical condition as it relates to the disability exceptions.”). 

[^ 22] If not present at the naturalization interview, the N-648 interpreter may be questioned via issuance of Form G-56 (Call-In Letter) or an FDNS site visit. As a last resort, USCIS may issue a subpoena to the interpreter for this purpose. Officers should consult with Office of the Chief Counsel before issuing a subpoena.

[^ 23] In the officer’s discretion, a good cause exception may be granted that would allow the witness to interpret. See The Role and Use of Interpreters in Domestic Field Office Interviews (PDF, 497.54 KB), PM-602-0125.1, issued January 17, 2017. See Part B, Investigation and Examination of Alien, Chapter 3, Naturalization Examination, Section A, Roles and Responsibilities, Subsection 3, Interpreters [12 USCIS B.3(A)(3)].

[^ 24] The interpreter must be under oath. See Part B, Investigation and Examination of Alien, Chapter 3, Naturalization Examination, Section A, Roles and Responsibilities, Subsection 3, Interpreters [12 USCIS B.3(A)(3)].

[^ 25] See The Role and Use of Interpreters in Domestic Field Office Interviews (PDF, 497.54 KB), PM-602-0125.1, issued January 17, 2017, and Part B, Investigation and Examination of Alien, Chapter 3, Naturalization Examination, Section A, Roles and Responsibilities, Subsection 3, Interpreters [12 USCIS B.3(A)(3)].

[^ 26] The list includes examples to guide officers when reviewing Form N-648 for sufficiency but is not comprehensive.

[^ 27] See 8 CFR 312.2(b)(2).

[^ 28] The officer may not find the Form N-648 insufficient solely because the Diagnostic Statistical Manual or International Classification of Diseases medical codes are missing in the form if the medical professional has provided a sufficient description of the clinical diagnosis for all the physical or developmental disabilities or mental impairments.

[^ 29] See Part J, Oath of Allegiance, Chapter 3, Oath of Allegiance Modifications and Waivers, Section C, Waiver of the Oath [12 USCIS-PM J.3(C)].

[^ 30] Before determining that a Form N-648 is insufficient due to missing information, officers should review all sections to confirm that the information needed does not appear in a different section of the form.

[^ 31] See Part B, Investigation and Examination of Alien, Chapter 3, Naturalization Examination, Section D, Subsequent Interview [12 USCIS-PM B.3(D)]. See Part B, Investigation and Examination of Alien, Chapter 6, USCIS Hearing and Judicial Review [12 USCIS-PM B.6]. See Request for a Hearing on a Decision in Naturalization Proceedings Under Section 336 (Form N-336).

[^ 32] See INA 312.

[^ 33] The officer may question the applicant about a Form N-648 with the use of an interpreter.

[^ 34] See 8 CFR 312.5(b).

[^ 35] For more information see Section G, Review of Medical Certification, Subsection 4, Credible Reasons to Doubt the Validity of Form N-648 [12 USCIS-PM E.3(G)(4)].

[^ 36] See Part B, Investigation and Examination of Alien, Chapter 6, USCIS Hearing and Judicial Review [12 USCIS-PM B.6].

[^ 37] See 8 CFR 336.2.