N-648 Disability Waiver by a Licensed Psychologist
USCIS requires the N-648 to be completed by a licensed physician (MD/DO) or a licensed clinical psychologist. Therapists, counselors, and master's-level clinicians cannot sign this form. Dr. Mantonya provides the doctoral-level evaluation USCIS demands. If a disability prevents you from learning English or civics for your citizenship exam, this evaluation documents that disability for USCIS.
USCIS Has Tightened N-648 Standards
Effective June 2025, USCIS Policy Alert PA-2025-10 expanded red flags and denial criteria for N-648 evaluations. Generic, template-style evaluations are now routinely denied.
-
Insufficient Nexus (Most Common Denial)
Simply listing a diagnosis without explaining how it specifically prevents learning English or civics is no longer accepted. The report must connect the disability to the inability to learn with clinical reasoning.
-
Boilerplate Language
Generic, template-style evaluations that could apply to any applicant are flagged as red flags. USCIS now looks for individualized assessment specific to this applicant.
-
Inconsistency with Prior Records
If the N-648 contradicts the I-693 civil surgeon exam (which showed no disabling condition), USCIS will deny. The evaluation must address any discrepancies directly.
What the N-648 Evaluation Includes
-
Comprehensive Cognitive Assessment
Cognitive screening and psychological testing to document the specific nature and extent of the disability. Testing tailored to the qualifying condition (PTSD, intellectual disability, dementia, TBI, or learning disability).
-
Specific Nexus Statement
Medically specific connection between the diagnosis and the inability to learn. Not "patient has PTSD" but "patient's PTSD causes concentration impairment and memory fragmentation that prevents retention of new English vocabulary, scoring in the 5th percentile on [specific measure]."
-
Duration and Prognosis
Clinical documentation that the condition has lasted 12+ months and is not expected to improve, with specific clinical reasoning supporting the prognosis.
-
I-693 Consistency Review
Review of prior civil surgeon examination to identify and address any discrepancies before USCIS flags them as inconsistencies.
-
Spanish Interpreter at No Extra Cost
Professional interpretation coordinated and included in the flat fee for all evaluations.
-
Unlimited Attorney Revisions
Full collaboration with the referring attorney until the N-648 meets all current USCIS requirements, including the 2025 tightened standards.
From Referral to Completed N-648
A straightforward process designed for busy attorneys. Refer your client, and Dr. Mantonya handles the rest.
Attorney Referral
Contact Dr. Mantonya with the client's condition, any prior I-693, and naturalization timeline.
Records Review
Review of medical records, prior I-693 exam, and any existing treatment documentation.
Clinical Evaluation
Cognitive assessment and psychological testing tailored to the specific qualifying condition.
N-648 Completed
Detailed, individualized N-648 with nexus statement and supporting documentation delivered in 5 to 7 business days.
Attorney Review
Review and revision at no extra charge to ensure compliance with current USCIS standards.
Transparent Flat-Fee Pricing
- Comprehensive cognitive and psychological assessment
- Specific nexus statement (disability to inability to learn)
- Duration and prognosis documentation
- I-693 consistency review
- Completed N-648 form signed by a licensed PsyD
- Spanish interpreter included at no extra cost
- Unlimited attorney revisions
N-648 Evaluation FAQ
Can my client's therapist or counselor complete the N-648?
No. USCIS requires the N-648 to be completed by a licensed physician (MD or DO) or a licensed clinical psychologist. Licensed clinical social workers (LCSWs), licensed marriage and family therapists (LMFTs), and other master's-level clinicians cannot sign this form. If your client's current provider is not a physician or psychologist, Dr. Mantonya can complete the N-648 evaluation.
What changed with the 2025 USCIS policy update?
USCIS Policy Alert PA-2025-10 (effective June 2025) expanded the list of red flags that trigger N-648 denials. Key changes include stricter scrutiny of the nexus between disability and inability to learn, flagging boilerplate or template-style evaluations, heightened review when the N-648 contradicts prior medical exams, and concerns about multiple submissions from different providers. Dr. Mantonya's evaluations are individualized and address each of these criteria.
Does the evaluation need to be completed within a certain timeframe?
Yes. The N-648 evaluation must be conducted within 6 months of filing the naturalization application (N-400). Dr. Mantonya schedules most evaluations within one week of referral, with the completed N-648 delivered in 5 to 7 business days, giving attorneys ample time to file within the required window.
Also Available
Ready to Get Started?
Contact us to discuss your case, confirm pricing, and schedule the evaluation. We respond within 24 hours.
Contact Us