The U.S. Citizenship and Immigration Service ("USCIS") have just announced a change in their policy regarding the validity period of a Form I-693, Report of Medical Examination and Vaccination Record, when filed in support of a Form I-485 Adjustment of Status Application.   Effective November 1, 2018, the I-693 medical report will be valid for two years from the date of submission to USCIS (and not one year as it is currently).   At the same time, USCIS are shortening the I-693 validity period to 60 days from the date the Civil Surgeon signs the I-693 medical exam (it used to be one year) and before the I-485 filing.

Update:  USCIS is temporarily waiving the 60-day validity requirement for I-485s filed before September 30, 2022.

Background and Reasons for the Change of Policy

Before 2002, USCIS considered a Form I-693 medical exam valid as long as it was filed within one year of the civil surgeon's signature.   Then, in 2014, USCIS changed their policy and restricted the validity of the submitted I-693 to one year which has resulted in a continuous loop of I-485 requests for evidence due to expiring (or expired) I-693 medicals.

The goal behind this policy change is to minimize the number of I-485 RFEs which are being issued only due to expiring I-693 medicals.

New Policy Requires Careful I-485 Planning and I-693 Medical Exam Timing

In conjunction with the two-year I-693 medical exam validity from the date of its submission, USCIS is now requiring I-693 medicals to be filed with I-485 within 60 days of the date the Civil Surgeon signs the medical exam.   This will require very careful planning for initial I-485 filings, I-485 RFE responses where medicals are requested or attending I-485 interviews where updated (or initial) I-693 medical exams must be submitted.

Under the prior policy, many I-485 applicants would go ahead and complete the I-693 medical exam and then keep it in their file for up to one year before they submit to USCIS.   This certainly helps with planning for an upcoming current priority date or upcoming I-485 interview when the medical exam is due to be submitted.     The new policy will require much closer coordination of the completion of the I-693 medical exam process and the filing of the medical exam with USCIS.

We invite you to review our I-485 filing strategies article for additional information and pointers regarding I-693 medical exams including whether to include the medical exam proactively or submit at a later time to USCIS.

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, 2018. Source: USCIS Policy Manual.

When did civil surgeon sign? I-693 remains valid for:
No more than 60 days before applicant filed I-485 with USCIS 2 years from date civil surgeon signed I-693
After applicant filed I-485 with USCIS 2 years from date civil surgeon signed I-693
More than 60 days before applicant filed I-485 with USCIS N/A – I-693 not valid at time applicant submits I-693 to USCIS

This validity chart makes it clear that an applicant can file their I-485 without the medicals in an effort to submit the application as quickly as possible. Then, after the I-485 is filed, the applicant can secure their medical records and complete their I-693 medical exam. Since the medical exam is valid for 2 years from the date the civil surgeon signs it (after I-485 filing), the applicant can submit the I-693 sealed medical exam envelope to USCIS during an interview, upon request by USCIS (in an RFE) or (possibly – see below) proactively send to USCIS.

Conclusion

It is helpful to see that USCIS has formulated a policy and a formal explanation to the medical exam validity period and its expansion from one to two years.   At the same time, we caution I-485 applicants to be mindful of the 60-day validity of the I-693 after the Civil Surgeon signs it (if the signature is done before the I-485 is filed).

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