USCIS I-693 Medical Exam Policy: Must be Filed with I-485 But Valid Indefinitely

The U.S. Citizenship and Immigration Service (“USCIS”) have recently changed their policy and starting December 2, 2024 they will require Form I-693, Report of Medical Examination and Vaccination Record to be submitted at the same time with a Form I-485 Adjustment of Status Application.

Separately, in a different recent policy change regarding the validity of the I-693 medical exam – for all medical exams signed by the civil surgeon after November 1, 2023 – USCIS will consider the I-693 medical exam valid indefinitely.   For medical exams signed before November 1, 2023, the validity term will remain two years from the date of the civil surgeon signature.

Background and Reasons for the Change of Policy

The policy change requiring I-693 medical exams to be submitted with I-485 application stems from efficiency needs – USCIS is hoping to avoid additional work and delays by not having to issue requests for evidence for medicals.

With respect to the validity of the medicals, USCIS has changed its policy multiple times over the past years.   The most recent change stems from the way civil surgeons (this is the technical term for the doctors who are authorized to perform USCIS-required medical exams) are required to report tuberculosis data.   Starting November 1, 2023 CDC requires civil surgeons to share data electronically with USCIS.     Additionally, civil surgeons have certain reporting obligations to their local health departments.    As a result, USCIS is now changing their policy that all medical exams signed after November 1, 2023 remain valid indefinitely.

USCIS still reserves the right to still request updated medical exams if they have a reason to believe that the existing I-693 no longer reflects the applicant’s medical condition.   For example, aging applicants or I-485 applicants with long-pending adjustment of status applications may still see requests for evidence for “updated” medicals.

New Policy Allows Flexibility But Still Requires Careful I-485 Planning and I-693 Medical Exam Timing

The additional flexibility means that applicants (especially from backlogged counties such as India or China) no longer have to worry about their medicals expiring before their adjustment of status application can be approved.

However, since the I-693 medicals now have to be provided together with and in support of the I-485 application filing, we still urge I-485 applicants to plan and start their I-693 medical process early to avoid delays in the I-485 filing in the event the medical exam is delayed (for example, due to missing vaccines or non-availability of appointments).

We urge I-485 applicants who are facing firm deadlines to file I-485 to plan and act early.   For example, applicants who may be subject to a cutoff date retrogression in the Visa Bulletin will have to ensure they file their I-485 before any retrogression takes effect.   Similarly, applicants who are running against status deadlines or aging out for children, must be very careful with the I-485 filing process and timeline.

We invite you to review our I-485 filing strategies article for additional information and pointers regarding I-693 medical exams.

I-693 Medical Exam Validity Rules

Below is a table which illustrates the validity of the I-693 medical exams for I-485 cases filed after November 1, 2023. Source: USCIS Policy Manual.

Again, for cases filed after December 2, 2024, USCIS will require the submission of a I-693 medical exam and, assuming this medical exam was signed by the doctor after November 1, 2023, this medical exam will remain valid indefinitely.

Pending I-485s: Should I Send My Medicals Proactively to USCIS?

The current USCIS policy requires that new I-485 filing include I-693 medicals.   However, for pending I-485, especially with respect to cases filed prior to 2023, the medical exams will expire and a new set will be needed.

Priority Date Not Expected To Be Current Soon

For most cases which do NOT expect to have a current priority date under Final Action in the near future or if obtaining the medicals will take time, in order to avoid delays in the I-485 submission,  it may make most sense to file the I-485 application and then work on obtaining the medicals for submission to USCIS at a later time.    The medicals can be submitted to USCIS proactively or in response to USCIS request.

First, USCIS generally does not like when applicants send documents relating to a case without being asked. As our readers and clients can understand, USCIS is dealing with huge volumes of correspondence and sending the medicals proactively and not in a response to a request increases not only the workload at USCIS but also increases the risk that a piece of correspondence may be lost and not make its way to the proper application file. For example, USCIS is often moving cases between services centers and field offices and it may be hard to know with certainty where a I-485 case file is located at an given time so that the medicals can be sent to that center.

Our general recommendation is to submit the medicals to USCIS only when asked to do so and under clear instructions on where to send. This is a much more efficient way to make sure that the medicals are sent to a specific request and to a specific USCIS office address. The risk of the medicals getting misplaced, delayed, or lost is, in our experience, extremely small. Also, we have found that filing the medicals in response to an RFE is likely to allow the case to be reviewed (and, hopefully, approved) faster.

Priority Date Current Or Expected To Be Current Soon:  Getting I-693 Ready and Waiting for Interview/RFE

For many I-485 applicants who have a priority date which is likely to be current in the following months (up to two years), it may make sense to aim to complete the medical exams and obtain the sealed I-693 medical exam envelopes. Subject to the medical exam validity rules discussed above, these applicants will be in a position to provide the medicals to USCIS promptly and ensure their case has the best chance of a faster approval.

Conclusion

While we understand the rationale for requiring I-693 medicals exams be submitted with I-485 applications, we expect that this requirement will create challenges for I-485 applicants, especially those who are under strict deadlines to file because some medical exams can take several weeks to complete.   This is especially critical for applicants who may be subject to cutoff date retrogression and may miss I-485 filing opportunity due to incomplete I-693 medical exam.    We urge early and careful planning of I-485 applications.

Our office is happy and available to assist with I-485 questions or needs.  Please do not hesitate to contact us or consider our consultation options or request I-485 filing quote.  Also, please subscribe to our free weekly newsletter to ensure that you obtain this and related immigration-related news and announcements.