On Dec. 2, 2024, U.S. Citizenship and Immigration Services (USCIS) announced that the agency will now require, with immediate effect, the concurrent filing of Form I-693, Report of Immigration Medical Examination and Vaccination Record, with all adjustment of status applications. The updated policy represents an abrupt departure from USCIS’ prior filing requirements for adjustment of status (AOS) applicants seeking lawful permanent residence in the United States, which had permitted applicants to file their green card applications without Form I-693, deferring what can be a time-consuming component of the AOS process to a later date during the application’s pendency. With this latest policy update, AOS applicants should consider planning ahead to ensure they can timely file for their green card as soon as eligible under the Department of State’s visa bulletin.

Form I-693’s Role in the Adjustment of Status Process

Form I-693, Report of Medical Examination and Vaccination Record, documents an immigrant’s admissibility to the United States, specifically speaking to the applicant’s health-related admissibility under the Immigration and Nationality Act (INA) § 212(a)(1). The form must be completed by a USCIS-designated civil surgeon following an examination that accounts for the applicant’s medical and vaccination history and verifies that they are not subject to any of the INA’s health-related grounds of inadmissibility. The form must be signed and sealed by the civil surgeon, remaining untampered with from its execution through its delivery to USCIS as part of the AOS application process.

Prior USCIS policy limited the form’s validity to two years from the date of the civil surgeon’s signature, which often required applicants to refresh medical examinations for cases subject to 24-month+ processing times, a fairly common scenario due to backlogs in immigrant visa availability under the Department of State’s annual immigrant visa quotas. In April 2024, USCIS updated this policy significantly, providing that a Form I-693 “properly completed and signed . . . on or after Nov. 1, 2023, does not expire and can be used indefinitely as evidence to show that the applicant is not inadmissible on health-related grounds.” The new policy on I-693 validity, however, endows the reviewing USCIS officer with the “discretion to request more evidence or a new or updated Form I-693 if they have reason to believe the applicant’s medical condition has changed since the civil surgeon signed the Form I-693, or that the Form I-693 submitted does not accurately reflect the applicant’s medical condition and the applicant may be inadmissible on health-related grounds.”

USCIS’ Updated Form I-693 Policy (December 2024)

Procedurally, USCIS has long permitted applicants to file Form I-693 after filing the AOS application. The prior policy proved particularly helpful during the height of the pandemic, when unpredictable service disruptions broadly afflicted industries and supply chains. The flexibility offered by the prior USCIS policy meant that applicants could ensure that their AOS applications were timely filed with USCIS as soon as eligible under the Department of State’s visa bulletin, deferring to a later date the potentially cumbersome task of identifying the civil surgeon, scheduling the medical examination, procuring vaccination records, completing the exam, and securing the signed and sealed medical examination form. For applicants that opted to defer submission of Form I-693, USCIS would typically request the medical examination form via a request for additional evidence (RFE) and, sometimes, during the green card interview (if applicable).

Under the agency’s new policy, applicants must file Form I-693 concurrently with the underlying AOS benefit request filed via Form I-485. USCIS’ new policy leaves little room for ambiguity or flexibility: file Form I-693 along with the remaining AOS application documents, “[o]therwise, we may reject your Form I-485.” Particularly because the visa bulletin cut-off dates are updated monthly, rejection of Form I-485 could, in turn, risk missing the applicant’s filing window entirely in the event of a retrogression in immigrant visa availability.

Filing Strategies for Prospective AOS Applicants

As USCIS’ new policy on Form I-693 filing adds to the components required at time of AOS filing, applicants may take steps to have the form completed at the same time as the remaining AOS application materials. Specifically, applicants may consider taking the following actions:

• Track down vaccination records in advance of filing. For those waiting to progress to the AOS step of the green card process (i.e., PERM pending or certified, I-140 pending, visa bulletin dates nearing, etc.), consider taking steps during the wait period to obtain vaccination records, which might be in an applicant’s home country and could take time to secure. Additionally, if vaccination records are in a language other than English, it may make sense to secure a certified translation in advance as well. This way, as soon as eligible to proceed with AOS filing, applicants will have the documents sure to be requested by the civil surgeon on hand with minimal lead time. In addition to vaccination records, retain important medical documents to provide to the civil surgeon on the day of the medical examination appointment.
• Identify a civil surgeon in advance. The civil surgeon will provide the applicant with an understanding of the examination’s contents, as well as a copy of the completed form. As outlined above, the form itself serves as documentary evidence of the applicant’s admissibility to the United States (i.e., their eligibility to receive a green card based on the inapplicability of health-related bars to adjustment of status under the INA), so it’s important that applicants feel comfortable enough with the civil surgeon’s office to ask questions and understand the contents of the form to be filed as part of the AOS application. Particularly with the upcoming transition to an administration that may place greater emphasis on enforcement and compliance, it is critical that applicants understand the contents of their Form I-693. Applicants should consider preparing early to maximize the time available to ensure that the completed Form I-693 aligns with their understanding of their medical and vaccination history.
• Schedule an appointment as soon as eligibility to file an AOS application is confirmed. As indicated above, expect at least one to three weeks lead time for an appointment with a civil surgeon, followed by at least one to two weeks to receive the completed signed and sealed form. As filing windows may be tight due to the risk of future visa bulletin retrogression, consider scheduling the medical examination with the civil surgeon as soon as feasible once eligible to proceed with the AOS process. Under the April 2024 indefinite validity policy, it may make sense to secure the sealed examination form in advance of becoming current for AOS filing, but even with the indefinite validity period afforded to Forms I-693 signed on or after Nov. 1, 2023, applicants should consider filing with a recently executed and sealed form.[1] Still, for some, the benefits of having a sealed medical examination ready to file once eligible may outweigh the costs of potentially having to redo the medical examination if the USCIS officer deems it necessary. 

Form I-693 is an essential component of every AOS application and, while the new USCIS policy governing the form’s filing reduces applicant flexibility in timing their medical examinations, applicants may take steps to ensure they are ready to obtain and file the I-693 when they become current for filing. 

[1] In 2018, the first Trump administration instituted a policy that increased the scope of cases that officers were directed to deny without issuance of an RFE or notice of intent to deny. If the incoming Trump administration reverts to such a deny-without-RFE policy, it may help to limit the application’s vulnerability to such denial grounds by filing with as recently dated documentation as possible.