Comment Submitted by Immigrant Legal Resource Center

Summary: 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.