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The new guidance states that while the N-648 should be submitted as an attachment to Form N-400, USCIS should accept a Form N-648 submitted after the applicant files the naturalization application6 with none of the strict conditions imposed by the previous guidance.
If the response to the request for evidence is determined to be insufficient, or if an applicant submits a new Form N-648 and it is deemed insufficient, the USCIS officer will provide the applicant with a second opportunity to retake each portion of the naturalization test including the civics and English language (
Use this form if you are applying for U.S. citizenship and need to request an exception to the English and civics testing requirements for naturalization because of physical or developmental disability or mental impairment.
After completion of the medical examination, the civil surgeon will give the applicant, the completed Form N-648 in a sealed envelope. The Sealed Envelope is Opened only by USCIS officials. The Seal should Never be Broken by the Applicant , his or her lawyer or any other Individual.
What type of medical conditions are required for an N-648? The applicant must have a medically determinable mental or physical disability or impairment that makes the person unable to learn to read, write, or speak English, or to learn U.S. history. Examples: Alzheimers and other forms of dementia.
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Illiteracy alone is not a valid reason to seek an exception to the English and civics requirements. In addition, advanced age, in and of itself, is not a medically determinable physical or developmental disability or mental impairment.

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