Definition
The N-648 Medical Disability Waiver is a form submitted to USCIS that exempts applicants with qualifying medical, developmental, psychological, or neurological conditions from the English and civics test during the naturalization process.
This waiver is protected under the Americans with Disabilities Act (ADA), which guarantees that individuals with disabilities are not excluded from the path to U.S. citizenship. For immigrants struggling with serious health conditions, the N-648 waiver is not a shortcut or handout it is a legal right.
U.S. Announces Return of Expanded Civics Test for Citizenship Applicants in 2025
The U.S. government has officially announced a significant update to the naturalization process: beginning in late 2025, applicants for U.S. citizenship will take a revised version of the 2020 Naturalization Civics Test, now reintroduced as the 2025 Naturalization Civics Test.
Key Highlights of the Update
- Return to the Expanded Test: USCIS will reinstate the 128-question civics test originally introduced in 2020, with slight modifications.
- Testing Format: Applicants will be asked up to 20 randomly selected questions. To pass, they must answer at least 12 correctly, just as under the 2020 rules.
- Early Stopping Rule: The 2025 version introduces a new feature if an applicant either reaches the passing threshold (12 correct answers) or fails by missing 9 questions, the test will stop without continuing to all 20 questions.
- Effective Date: The new format will apply to applications filed on or after October 20, 2025.
- Transition Period: Applicants who file before October 20, 2025 (or within 30 days of the announcement) will continue to take the 2008 version of the test.
- Senior Applicants: Long-term residents aged 65 or older (with at least 20 years of lawful U.S. residence) will still take a simplified 10-question test, needing to answer 6 correctly to pass. Depending on their filing date, their test questions will be drawn from either the 2008 or the 2025 set.
Why the Change?
According to USCIS, the move is intended to ensure the civics test provides a broader and more comprehensive measure of applicants’ knowledge of U.S. history, government, and democratic principles.
The agency also emphasized
- English proficiency and civics knowledge remain essential requirements.
- There will be stricter evaluation of “good moral character”, with expanded verification measures such as community background checks.
Potential Impact
- Preparation Challenges: Applicants currently studying with the 2008 question set may need to adjust their preparation strategies for the expanded 128-question version.
- Testing Experience: The early stopping rule could shorten test times, but it may also add pressure for applicants who struggle with English or civics knowledge.
- Immigrant Rights Concerns: Advocacy groups may raise concerns that the expanded test creates new barriers, particularly for applicants with limited English skills or lower access to civics education.
When to Use
You may qualify for an N-648 waiver if a licensed medical or psychological professional determines that your condition makes it unreasonably difficult to learn or recall English or civics.
Common qualifying conditions include:
- Dementia, brain injury, or memory impairments
- Severe learning disabilities (e.g., dyslexia)
- PTSD, major depressive disorder, or severe anxiety
- Developmental or intellectual disabilities
- Neurological conditions affecting comprehension or communication
The waiver ensures that disability does not become a locked door on the American dream. Even with the harder USCIS citizenship test 2025 (128 questions instead of 100), ADA rights still apply.
Required Documents
Applying for the N-648 waiver requires:
- Completed Form N-648 signed by a licensed medical professional
- Supporting medical records consistent with the diagnosis
- Psychological or neuropsychological evaluation reports (if applicable)
- Detailed clinical explanation describing how the condition prevents learning or recalling English/civics
PECGNA clinicians provide immigration-focused psychological evaluations designed to meet USCIS standards. Every report is also reviewed by immigration attorneys to ensure legal accuracy.
Process & Timeline
The process of applying for the N-648 waiver includes:
- Schedule a medical/psychological evaluation (telehealth or in-person)
- Undergo a full assessment with PECGNA’s clinicians
- Report drafted and reviewed by both clinicians and immigration legal professionals
- Submit N-648 form together with Form N-400 (naturalization application)
Estimated Timeline: Typically 4–5 day depending on urgency and case complexity. PECGNA also offers expedited evaluations for urgent filings.
Cost & Payment
- Varies by state and case complexity
- PECGNA offers flexible payment plans to remove financial barriers
- Expedited turnaround services are available for urgent applications
Understanding the cost implications of applying for an N-648 waiver is essential. PECGNA ensures affordability while maintaining clinical and legal precision.
Case Examples & Attorney Q&A
- Attorney Question: “My client has severe PTSD and depression causing memory loss. Can they qualify for N-648?”
- Answer: Yes. If clinical evaluation confirms the condition significantly impacts learning or recall, the waiver can be approved. PECGNA ensures the report is both clinically detailed and legally precise.
Case Example: An Alzheimer’s patient unable to recall civics questions was granted an N-648 waiver and successfully naturalized. Attorneys can directly refer clients securely to PECGNA for evaluation and legal-reviewed documentation.
ADA Rights and the Harder USCIS Citizenship Test
On September 18, 2025, the New York Times reported that USCIS increased the civics test from 100 to 128 questions, requiring applicants to answer 12 out of 20 correctly starting October 20, 2025.
For many, this raises stress and barriers. But ADA protections remain firm. With the N-648 waiver, qualifying applicants are not left behind they are supported with equal access to citizenship. Learn more about ADA disability rights.
Call to Action
The test may be harder, but your rights remain strong. With PECGNA, you gain more than an evaluation you gain an advocate who understands the law, the psychology, and the compassion this process requires.
Call: (949) 949-1002
Learn more: PECGNA N-648 Services
Email: hello@pecgna.com
Frequently Asked Questions (FAQ)
Q1: Who qualifies for the N-648 medical disability waiver?
A1: Individuals with medical, psychological, developmental, or neurological conditions that prevent them from learning English or civics may qualify.
Q2: Does the harder USCIS citizenship test in 2025 affect N-648 waivers?
A2: No. ADA protections still apply. If you qualify medically, the waiver exempts you from the test regardless of difficulty.
Q3: What documents are required for an N-648 waiver application?
A3: A completed N-648 form signed by a licensed medical professional, medical records, and detailed clinical evaluations.
Q4: How long does the N-648 waiver process take?
A4: Typically 1–3 weeks. PECGNA also offers expedited services for urgent applications.
Q5: How much does an N-648 waiver evaluation cost?
A5: Costs vary, but PECGNA provides flexible payment plans to ensure affordability.
Q6: Can immigration attorneys refer clients directly to PECGNA?
A6: Yes. Attorneys can securely submit client referrals for legal-reviewed evaluations through PECGNA’s referral system.
Q7: Why choose PECGNA for N-648 evaluations?
A7: PECGNA combines doctorate-level psychologists, immigration attorney review, telehealth in all 50 states, multilingual clinicians, and UN-recognized credibility.
