Medical Certification for Disability Exceptions

OMB Control No: 1615-0060	ICR Reference No: 201909-1615-003
Status: Active	Previous ICR Reference No: 201809-1615-001
Agency/Subagency: DHS/USCIS	Agency Tracking No: N-648
Title: Medical Certification for Disability Exceptions
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 07/23/2020
Retrieve Notice of Action (NOA)	Date Received in OIRA: 12/06/2019
Terms of Clearance: The agency is receiving a 16 month approval on this collection of information. When the agency next seeks comment on this collection, it shall explicitly seek comment on the entire collection regardless of whether the agency is anticipating any revisions to the collection of information.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2021	36 Months From Approved	05/31/2021
Responses	4,138	0	4,138
Time Burden (Hours)	10,014	0	8,276
Cost Burden (Dollars)	213,107	0	202,762

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Abstract: USCIS uses the Form N-648 to substantiate a claim for an exception to the requirements of section 312(a) of the Immigration and Nationality Act. By certifying Form N-648, the doctor states that an applicant filing an Application for Naturalization, Form N-400, is unable to complete the English and/or civics requirements because of a physical or developmental disability or mental impairment(s).

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Authorizing Statute(s): US Code: 8 USC 1423 Name of Law: U.S. Code

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	84 FR 17870	04/26/2019
30-day Notice:	Federal Register Citation:	Citation Date:
	84 FR 46962	09/06/2019
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 1

IC Title Form No. Form Name Medical Certification for Disability Exceptions Form N-648 Medical Certification for Disability Exceptions

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	4,138	4,138	0	0	0	0
Annual Time Burden (Hours)	10,014	8,276	0	1,738	0	0
Annual Cost Burden (Dollars)	213,107	202,762	0	0	10,345	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: There is a 1,738 hour increase in the annual time burden of this information collection due to the addition of language in the form and instructions, specifically the addition of information related to a Policy Manual update that requires the N-648 be filled with the N-400; requesting new information regarding the applicant's impairment or disability in the form; and the addition of examples to help the respondent (doctor) complete the form in the instruction. The program changes impacted only the time burden, but did not impact the population. The increase in cost burden is a result of a change in methodology. Specifically, USCIS increased the estimated average out-of-pocket costs to respondents between the last N-648 action and this revision. With this revision the increase cost reflects the increased estimated cost.

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Annual Cost to Federal Government: $1,390,368

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     Yes

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

Agency Contact: Megan Barker 202 272-9135 [email protected]

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
		(a) It is necessary for the proper performance of agency functions;
		(b) It avoids unnecessary duplication;
		(c) It reduces burden on small entities;
		(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;
		(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
		(f) It indicates the retention periods for recordkeeping requirements;
		(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:
			(i) Why the information is being collected;
			(ii) Use of information;
			(iii) Burden estimate;
			(iv) Nature of response (voluntary, required for a benefit, or mandatory);
			(v) Nature and extent of confidentiality; and
			(vi) Need to display currently valid OMB control number;
		(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.
		(i) It uses effective and efficient statistical survey methodology (if applicable); and
		(j) It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Certification Date: 12/06/2019

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