Agency Information Collection Activities; Revision of a Currently Approved Collection: Medical Certification for Disability Exceptions

The commenter, who appears to be a legal representative or consultant (referencing "my clients"), argues that the proposed changes to the N-648 Medical Waiver will make it harder for doctors to complete the forms. They contend that the increased length and repetition will lead to more exclusions from naturalization for individuals with disabilities.

Project Citizenship, a nonprofit providing citizenship legal services, opposes the proposed revisions to Form N-648 because they expand the number of questions and the level of detail required from medical professionals. They argue that the proposed changes exceed regulatory requirements, create unnecessary administrative burdens, and will make it harder for vulnerable applicants with disabilities to obtain U.S. citizenship.

The commenter, a former policy advocate and trainer for legal service providers, opposes the proposed changes to Form N-648. They argue that the new form is excessively long, repetitive, and imposes requirements that exceed current laws, creating significant barriers for people with disabilities seeking U.S. citizenship.

The commenter is a social service provider for the Illinois statewide Comprehensive Class Member Transition Program representing individuals with disabilities. They argue that the N-648 medical exemption process is already complex and burdensome for their clients, and they urge DHS and USCIS to avoid any policy changes that would further complicate or restrict access to this process.

The Immigrant Legal Resource Center (ILRC) opposes the proposed revisions to Form N-648, arguing that the changes create unauthorized eligibility standards, violate the Administrative Procedures Act and Paperwork Reduction Act, and impose an undue burden on applicants and physicians. They specifically object to requirements for "regularly treating" physicians, "curing" disabilities, and in-person examinations, while supporting the removal of the oath waiver question.