English test exemptions: 50/20, 55/15 and Form N-648

Most applicants for citizenship take two tests at the interview: English and civics. Two rules based on age and years as a permanent resident remove the English test, and you can then take civics in your own language. A third rule, for people with a medical disability, can remove either test or both. This guide explains who each one covers and what it changes.

Rows of people standing during a naturalization ceremony in a crowded hall with red walls. — New citizens at a naturalization ceremony in Baltimore, July 4, 2015. Photo: U.S. Department of Homeland Security, public domain, via Wikimedia Commons.

The two age and residence exemptions

You do not have to take the English test (reading, writing and speaking) if, on the day you file Form N-400, one of these is true:

You are 50 or older and have lived in the United States as a lawful permanent resident for at least 20 years. People call this the 50/20 exemption.
You are 55 or older and have lived in the United States as a lawful permanent resident for at least 15 years. This is the 55/15 exemption.

You need both numbers in the same line. Age alone does not do it, and neither do the years alone. Both exemptions are in the USCIS Policy Manual, Volume 12, Part E, Chapter 2, and USCIS repeats them on its exceptions and accommodations page.

You still take the civics test, in your language

The exemptions cover English only. The civics requirement stays. What changes is the language you answer in. The Policy Manual puts it in one sentence, right under the two exemptions:

"The alien may take the civics test in his or her language of choice with the use of an interpreter."

Nothing in the exemption changes the civics test itself. Under the current version you are still asked up to 20 questions from the list of 128, and you still need 12 correct answers. The difference is that you hear each question through the interpreter and answer in your own language. So you study the same questions as everyone else, and you can learn the answers in the language you will use on the day.

If you are studying in Spanish or another language, it helps to learn the official English answer next to your translation. The interpreter has to carry your answer back into English for the officer, and knowing what the official answer says makes it easier to give one that translates cleanly. Each of the 128 questions on this site has its official answers in English and an explanation of why they are right.

Who brings the interpreter

You do. USCIS says it plainly on its exceptions page: if you take the civics test in your native language, you must bring an interpreter with you to your interview, and that person must be fluent in both English and your native language.

The Policy Manual chapter on the naturalization examination adds the rest of the rules for interpreters:

You bring the interpreter at your own expense.
The interpreter translates what you and the officer say word for word, without adding opinions, comments or answers of their own.
At the interview, the interpreter completes an interpreter's oath and a privacy release statement, and hands in a copy of a government-issued identification.
The interpreter should be a disinterested party.
The officer can disqualify an interpreter you bring if their participation compromises the integrity of the examination.
If the officer speaks your language fluently, the officer may hold the examination in that language.

"Disinterested party" means someone with nothing at stake in your case. The Policy Manual does not list who counts, so when you choose, think about whether the officer could doubt that the person is translating your words and not helping you answer.

How the years and the age are counted

Both numbers are measured on the date you file, not on the date of the interview. The Policy Manual says "at the time of filing for naturalization" for each exemption, and the exceptions page says the same.

The years start when you became a lawful permanent resident. The federal regulation behind the rule, 8 CFR 312.1(b), describes them as periods totaling the required number of years "subsequent to a lawful admission for permanent residence". Two things follow from that wording. Time you spent in the country before your green card, in another status, is not part of the count. And the count is of time living in the United States, added up across periods.

Because the date of filing is the one that counts, turning the right age a few months after you file does not help. The exemption depends on what was true the day USCIS received your application.

Five examples

These people are invented. Their ages and years are what they had on the day they filed.

Applicant A is 53 and has been a permanent resident for 21 years. That meets 50/20, so A is exempt from English and takes civics in their language.
Applicant B is 57 with 16 years. B is short of the 20 years that 50/20 asks for, but meets 55/15. Same result as A: no English test, civics in their own language. B does not have the 65/20 special consideration, so B studies the full list.
Applicant C is 54 with 19 years. C misses 50/20 by 1 year of residence and 55/15 by 1 year of age. Neither exemption applies, and C takes both tests in English.
Applicant D is 54 with 16 years, and turns 55 a month after filing. Because age is measured at filing, D does not meet 55/15 for this application. Filing after the birthday would have changed that.
Applicant E is 66 with 20 years. E meets both English exemptions and also the 65/20 special consideration, which shortens the civics list.

How this differs from the 65/20 rule

The 65/20 special consideration is a separate provision. The 50/20 and 55/15 exemptions remove the English test. The 65/20 rule changes the civics test: a shorter designated list and fewer questions. Anyone who qualifies for 65/20 also meets 50/20, which is why the two usually arrive together, as with Applicant E. Someone like Applicant B has the English exemption and the regular civics test.

The 65/20 guide covers that rule in full, with the designated questions and a practice mode that uses only them.

The medical disability exception: Form N-648

The third route has nothing to do with age. U.S. law provides an exception for applicants who cannot meet the English requirement, the civics requirement or both because of a physical or developmental disability or a mental impairment. You ask for it with Form N-648, Medical Certification for Disability Exceptions. The rules are in Volume 12, Part E, Chapter 3 of the Policy Manual, and the form is on its official USCIS page.

The condition has to be "medically determinable", which the regulations define as one that can be shown by medically acceptable clinical or laboratory diagnostic techniques, and it has to have lasted or be expected to last at least 12 months. It also has to be the reason you cannot meet the requirement even with reasonable accommodations.

Who signs it

Only three kinds of licensed professionals can certify the form: medical doctors, doctors of osteopathy and clinical psychologists. They must be licensed in a U.S. state, the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands or the Northern Mariana Islands. They certify the form under penalty of perjury.

The professional has to examine you, in person or, where state law allows it, through a real-time telehealth examination. On the form they identify each disability or impairment, explain how it prevents you from learning or showing knowledge of English, civics or both, and state that it is not caused by illegal drug use. If an interpreter helped during the medical examination, the interpreter signs the interpreter section of the form; after a telehealth examination, the medical professional completes that certification instead.

The form must be certified no more than 180 days before you file the N-400. You normally submit it together with the N-400. USCIS can accept it later, even at the interview, if you show extenuating circumstances, such as a condition that began or got worse after you filed.

There is no filing fee for Form N-648, although the medical professional may charge for the examination and for filling out the form. USCIS publishes warnings about scams involving fake medical certifications on the form's page, and suggests checking a professional's license with your state medical board.

It is a request, and the officer decides

Filing an N-648 does not exempt you on its own. The officer reviews the form for sufficiency: that it is complete and signed, that it matches the rest of your record, and that the explanation is specific to you and to your condition, not a generic paragraph. You carry the burden of proof, by a preponderance of the evidence.

If the officer finds the form sufficient, USCIS waives the requirement the professional indicated. If the professional said you cannot meet the English speaking requirement, the interview and the civics test go ahead in your preferred language with an interpreter.

If the officer finds the form insufficient, the interview continues as if you had never filed it, and you get the chance to take every part of the English and civics tests. You still have the usual 2 attempts. So even with an N-648 on file, preparing for the tests is the safe plan: the practice test works for that.

An exception is different from an accommodation

An accommodation changes how you take the test without removing it. The Policy Manual gives sign language interpreters, extra time and testing at an off-site location as examples. You request an accommodation separately, not with Form N-648. Someone who needs both, such as a deaf applicant who also cannot meet the requirements because of an impairment, can file the N-648 and ask for a sign language interpreter at the same time.

Where to go from here

The interview guide describes the appointment step by step. If you do not qualify for an exemption, the English test practice works through the reading and writing sentences with the official vocabulary lists. For anything about your own case, the USCIS Contact Center is the channel that can look it up, and USCIS keeps a page on finding legal help if your situation needs it.