A semiconductor device includes a substrate and a first gate oxide layer overlying a first device region and a second device region in the substrate, a first gate in the first device region, and a second gate and a third gate in the second device region. The device also has a first dielectric layer with a first portion disposed on the first gate, a second portion disposed adjacent a sidewall of the first gate, and a third portion disposed over the third gate. An inter-gate oxide layer is disposed on the first gate and between the first portion and the second portion of the first dielectric layer. A fourth gate overlies the second gate oxide layer, the inter-gate oxide layer, and the first portion and the second portion of the first dielectric layer in the first device region. A fifth gate overlies the third portion of the first dielectric layer which is disposed over the third gate in the second device region.