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September 15, 2026
GWP IMMIGRATION LAW
Not Every Medical Professional Can Sign This Form
USCIS accepts Form N-648 from only three types of licensed professional, and rejects it automatically from anyone else, regardless of their role in your care.
The rule itself hasn’t changed, but USCIS is reading every signature more closely since it tightened its fraud screening for the N-648 in 2025.
Updated September 15, 2026 · GWP Law · Las Vegas, NVTHE CONTEXT
Who USCIS Will Accept — and Who It Won’t
For the legal basics behind this exemption, see our overview of Form N-648.
Federal regulation limits who may certify Form N-648 to three categories of licensed professional.
Under 8 CFR 312.2(b), only a medical doctor, a doctor of osteopathic medicine, or a licensed clinical psychologist may sign it.
Each must be licensed to practice in a U.S. state, the District of Columbia, or a U.S. territory such as Puerto Rico, Guam, or the Northern Mariana Islands, according to USCIS’s own guidance for medical professionals completing the form.
Nurse practitioners, physician assistants, and licensed clinical social workers are not authorized to sign the N-648 — even when they provide most of the applicant’s ongoing care, and even when a supervising physician reviews their work.
USCIS also requires that the certifying professional personally examine the applicant, either in person or through a synchronous, real-time telehealth visit that complies with that state’s telehealth licensing rules, per the USCIS Policy Manual.
A pre-recorded questionnaire, a phone-only consultation, or a records review without an actual examination does not meet that standard.
Source: USCIS, Information for Medical Professionals Completing Form N-648; 8 CFR 312.2(b).
A REAL CASE
A Signature That Never Should Have Been on the Form
A man came to me with an N-648 that his community clinic’s nurse practitioner had already completed and signed.
I had to tell him that USCIS would reject the form outright, no matter how accurate the diagnosis was, because a nurse practitioner isn’t authorized to sign it.
I located a licensed clinical psychologist who could see him within the month for a full evaluation, done from scratch.
The corrected N-648 was accepted at his interview without issue.
Before You Schedule the Evaluation
THE PATH FORWARD
Choosing the Right Evaluator Matters as Much as the Diagnosis
An N-648 signed by the wrong professional is rejected before USCIS ever weighs the medical evidence inside it.
We regularly refer clients to qualified MDs, DOs, and clinical psychologists experienced with this specific form, so the evaluation meets USCIS’s standard the first time.
If your citizenship case is also complicated by a criminal history, that should be reviewed at the same time — see, for example, our guide on applying for citizenship with a pending criminal case — since scheduling and evidence gathering often overlap.
Our citizenship and naturalization team can refer you to an evaluator experienced with this exact form.
References
- 8 CFR § 312.2(b) — Medical certification requirement
- USCIS, Information for Medical Professionals Completing Form N-648
- USCIS Policy Manual, Volume 12, Part E, Chapter 3 — Medical Certification for Disability Exceptions (Form N-648)
Need a referral to a qualified N-648 evaluator?
We can help you find one, and review your case before you file.
Book a Consultation →This article is for informational purposes only and does not constitute legal advice. Consult a qualified immigration attorney before taking any action. · Last verified: August 28, 2026 · Reviewed by: Kathia Quirós, Immigration Attorney · GWP Immigration Law
