Who Can Certify Form N-648: Authorized Signers and Requirements

Only three types of licensed professionals are authorized to certify Form N-648: a medical doctor (MD), a doctor of osteopathy (DO), or a clinical psychologist. Whoever signs must hold a current, unrestricted license to practice in the United States or a U.S. territory. A form signed by any other type of provider is treated as if no certification was filed at all, so confirming credentials is the first step before scheduling an exam or paying for a report.

The Three Authorized Professionals

Federal regulation limits certification authority for the disability exception to medical doctors, doctors of osteopathy, and clinical psychologists licensed to practice in the United States.¹ The license must come from one of the fifty states, the District of Columbia, or a U.S. territory. The regulation specifically names Guam, Puerto Rico, and the U.S. Virgin Islands.

The credential itself must be in good standing. USCIS can verify a certifying professional’s license through state boards, and a signature from a provider whose license is expired, suspended, or restricted is not accepted.² The professional’s license number and the state that issued it appear directly on the form so an officer can confirm status.

Which of the three categories fits depends on the applicant’s condition. A medical doctor or doctor of osteopathy typically certifies physical disabilities, neurological conditions, and medical illnesses that affect learning or communication. A clinical psychologist typically certifies cognitive, developmental, and mental health conditions. Some cases fit either lane; what matters legally is that the signer holds one of the three qualifying licenses.

Providers Who Cannot Sign

Every other type of healthcare provider falls outside the regulation’s scope. Nurse practitioners cannot sign Form N-648. Neither can physician assistants, licensed clinical social workers, therapists, counselors, or psychiatrists who hold only a non-medical degree. This limit is strict. It doesn’t matter how well the provider knows the patient, how thorough the evaluation is, or how detailed the report reads. If the signature is not from an MD, DO, or clinical psychologist, USCIS will reject the certification.

The restriction is deliberate. USCIS relies on the certifying professional’s clinical training to judge how a specific disability keeps someone from learning English or civics. That diagnostic judgment is the reason the regulation names these three license types and no others.

What the Signing Professional Must Do

The certifying professional has to personally examine the applicant before signing. Staff can help with administrative sections of the form, but the clinical evaluation, the diagnostic conclusions, and the attestation are the signing professional’s sole responsibility.³ A form completed without an actual examination is one of the clearest fraud indicators USCIS looks for.

The evaluation looks at how the applicant’s disability affects the ability to learn, retain, and demonstrate knowledge. Cognitive function, memory, language processing, and any physical limitations that interfere with reading, writing, or speaking all come into play. Every conclusion has to rest on standardized clinical or laboratory diagnostic methods. General observations or brief screenings will not survive an officer’s review.

Telehealth Examinations

USCIS accepts certifications based on telehealth exams, as long as the medical professional follows the telehealth laws of the state where they are licensed.³ If those state rules are not met, USCIS may ask for a new form. The professional is still the one performing the exam and signing the certification; telehealth changes the setting, not who is authorized.

What the Professional Signs

The signing professional certifies several things under penalty of perjury. The form has to include a clinical diagnosis for every condition affecting the applicant’s ability to meet the English or civics requirements, with each diagnosis carrying a standardized code from either the DSM or the ICD.² The professional describes the clinical or laboratory techniques used to reach the diagnosis, gives the date they last examined the applicant, and explains how, specifically, the diagnosed condition prevents the applicant from learning or demonstrating knowledge of English, civics, or both.³

Two additional attestations are required. The professional must confirm the disability has lasted or is expected to last at least twelve months.² If the condition does not meet that threshold, the applicant is not eligible and the professional should not complete the form. The professional also has to attest that the disability is not caused by illegal drug use, because cognitive impairment from illegal drug use is specifically excluded from the disability exception by federal regulation.⁴

Business address, phone number, license number, and licensing state all go directly on the form. The signature block certifies that everything is true and correct based on the professional’s clinical findings. Every field must be filled in; blanks give the processing center grounds to reject the certification.

Why Getting the Signer Right Matters

A Form N-648 signed by an unauthorized provider does more than delay a case. USCIS treats it as if no certification was ever filed, meaning the applicant is back to taking the standard English and civics exams. If the applicant fails after two attempts, the naturalization application is denied.³

The stakes for the signing professional are also real. Because the form is signed under penalty of perjury, knowingly placing false information on it exposes the signer to criminal prosecution, with penalties of up to ten years in prison for a first or second offense.⁵ Civil penalties run from $250 to $2,000 per fraudulent document, rising to $2,000 to $5,000 for repeat offenders.⁶ State licensing authorities can suspend or revoke the medical license on top of federal consequences.

USCIS has flagged specific patterns that trigger fraud scrutiny: the certifying professional is under investigation for healthcare or immigration fraud, the applicant paid for the form without an actual examination, or the interpreter used during the exam is tied to known N-648 fraud schemes.³ Before choosing a provider, verify that they are an MD, DO, or clinical psychologist with a current, unrestricted license, that their disciplinary record is clean, and that they intend to conduct a genuine clinical evaluation rather than produce paperwork on demand.

One Situation Where a Doctor Isn’t Needed

Not every applicant who struggles with the English or civics tests needs a medical certifier. Federal regulation provides separate age-based exceptions that require no medical documentation of any kind.⁴ An applicant who is age 50 with 20 years of permanent residency, age 55 with 15 years, or age 65 with 20 years qualifies for a waiver of the English requirement without a Form N-648.⁷ If the barrier is English rather than a diagnosable disability, the question of who can certify the form doesn’t arise; no medical professional needs to sign anything.

1
eCFR. 8 CFR 312.2 – Knowledge of History and Government of the United States
2
U.S. Citizenship and Immigration Services. Form N-648 – Medical Certification for Disability Exceptions
3
U.S. Citizenship and Immigration Services. USCIS Policy Manual – Medical Disability Exception, Form N-648
4
eCFR. 8 CFR 312.1 – Literacy Requirements
5
Office of the Law Revision Counsel. 18 USC 1546 – Fraud and Misuse of Visas, Permits, and Other Documents
6
Office of the Law Revision Counsel. 8 USC 1324c – Penalties for Document Fraud
7
U.S. Citizenship and Immigration Services. USCIS Policy Manual – English and Civics Testing