*** The Health Care Programs Manual (HCPM) has been replaced by the Minnesota Health Care Programs Eligibility Policy Manual (EPM) as of June 1, 2016. Please refer to the EPM for current health care program policy information. ***

Chapter 11 - Citizenship and Immigration Status

Effective:  June 1, 2012

11.05 - U.S. Citizenship and Identity Verification Requirements

Archived:  June 1, 2016 (Previous Versions)

U.S. Citizenship and Identity Verification Requirements

Minnesota Health Care Program (MHCP) applicants and enrollees who state they are U.S. citizens are required to verify citizenship and identity as a condition of eligibility unless they are exempt.

Note:  Noncitizens must cooperate with requirements to verify their immigration status as a condition of eligibility for any type of MHCP coverage.

People are only required to provide verification of citizenship and identity once. This documentation is a permanent part of the case file. Do not request additional proofs when verification is already in the case record. Request further documentation only if later evidence raises a question of the person’s citizenship or identity.

What Is A U.S. Citizen?

Who Is Required to Verify U.S. Citizenship and Identity?

Exempt from Citizenship and Identity Verification Requirement.

Who Is Not Required to Verify U.S. Citizenship and Identity?

When Must Verification Occur?

Steps to Verify Citizenship and Identity.

Assisting Clients with Documentation Requirements.

Transfer and Retention of Documentation.

Related Topics.

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What Is A U.S. Citizen?

A U.S. citizen is:

l  A person (other than the child of a foreign diplomat) who was born in the United States or in the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, or the Northern Mariana Islands who has not renounced or otherwise lost his or her citizenship.

l  A person born outside of the United States to at least one U.S. citizen parent (sometimes referred to as a ’’derivative citizen’’).

l  A naturalized U.S. citizen.

Consider U.S. nationals to be U.S. citizens for purposes of Social Security and for citizenship verification purposes. A U.S. national is a citizen or certain noncitizen that owes permanent allegiance to the U.S. and may enter and work in the U.S. without restriction. Currently, the only U.S. noncitizen nationals are (1) persons born in American Samoa or Swain’s Island after December 24, 1952; and (2) residents of the Northern Mariana Islands who opted to become U.S. nationals instead of U.S. citizens.

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Who Is Required to Verify U.S. Citizenship and Identity?

Verification of U.S. citizenship and identity is required as a condition of eligibility for the following programs (unless the client is exempt):

l  MinnesotaCare for families with children (this includes adults with children, pregnant women, and children under 21).

l  MinnesotaCare for adults without children.

l  Medical Assistance (MA), including long-term care (LTC), waiver programs and program IM.

l  Minnesota Family Planning Program (MFPP).

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Exempt from Citizenship and Identity Verification Requirement

The following people are exempt from the U.S. citizenship and identity verification requirement:

l  People enrolled in or entitled to enroll in Medicare. Citizenship and identity has already been verified by the Social Security Administration (SSA).

Note: This includes people who are applying for or enrolled in the Medicare Savings Programs.

l  People who receive or previously received SSI. Use a SVES query to confirm current or past receipt of SSI.

l  People who receive or previously received RSDI income due to disability (also known as SSDI).

Note:  People who receive RSDI retirement or survivor’s insurance benefits are not exempt from this requirement unless they meet another condition for exemption (such as enrollment in Medicare).

To determine if a client receives or previously received RSDI based on a disability, check the BNDX interface and case record for information from SSA indicating a disability, request a copy of the most recent RSDI award letter, or obtain a signed release from the client and contact SSA directly.

l  Children eligible for MA who receive IV-E or non-IV-E foster care.

l  Children eligible for MA who receive IV-E or state-funded Adoption Assistance.

l  Auto newborns and children who were previously enrolled as auto newborns.

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Who Is Not Required to Verify U.S. Citizenship and Identity?

In addition to people who meet one of the exemptions noted above, do not require verification of citizenship and identity as a condition of eligibility from the following:

l  MinnesotaCare for volunteer firefighters and ambulance attendants applicants and enrollees.

l  Clients who previously provided verification of U.S. citizenship and identity.

l  Noncitizens.

l  Food Support and cash program applicants who are not requesting MA, MinnesotaCare or MFPP.

l  HIV/AIDS program applicants and enrollees.

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When Must Verification Occur?

For all health care programs, begin the citizenship and identity verification process at initial case processing.

Most MA applicants will have citizenship and identity verified electronically through the Social Security Administration (SSA) data match. The SSA data match is an electronic interface between the Social Security Administration and DHS that verifies U.S. citizenship and identity.

MinnesotaCare and MFPP applicants must submit paper verification of citizenship and identity if their citizenship and identity was not previously verified through the SSA data match or another source. Clients have at least 90 days to provide verification of citizenship and identity once verification has been requested.

Clients who fail to cooperate with the citizenship and identity verification requirement are not eligible for any MHCP until they cooperate. When clients reapply after being denied or closed for failure to cooperate with citizenship verification requirements, they must provide verification before they can be approved for coverage. Once verification of citizenship and identity is received, clients are eligible for ongoing and retroactive eligibility.

Clients who are otherwise eligible for MA or MinnesotaCare, but fail to verify citizenship and identity are not eligible for state-funded MinnesotaCare for adults without children.

Steps to Verify Citizenship and Identity

1. At application and renewal, check the case record to determine if citizenship and identity was previously verified.

n  Review all case records, including MAXIS, MMIS, MFIP, Food Support, child support and childcare records, to determine if the client previously provided verification of citizenship and identity or if verification was previously verified through the SSA data match.

n  If the client ever received services from a social worker or case manager, contact them to determine if they have documents verifying citizenship and identity.

n  If the client previously received assistance from another agency (county, tribe or MinnesotaCare Operations), ask that agency to provide copies of the paper verification.

Note:  The agency in possession of paper citizenship or identity verification must provide copies for the current case record.

n  If paper copies were used to verify citizenship and identity previously, but the case record has been purged or destroyed, request verification citizenship and identity again.

2. Depending on the program, follow the appropriate process for verifying citizenship and identity.

3. Enter a separate case note with detailed information about citizenship and identity verification, cooperation or exemption for all applying household members on each case. At a minimum, the first line must state in capital letters, "CITIZENSHIP AND IDENTITY" so that the information can be easily located for reviews and audits.

4. Approve health care if the client meets all other eligibility requirements, except for verification of citizenship and identity.

Exception:  Do not approve health care until the client submits verification of citizenship if the verification was previously requested and the client failed to cooperate.

Assisting Clients with Verification Requirements

Assist clients who need to submit paper verification of citizenship and identity if they ask for help or are having difficulty obtaining documents. MinnesotaCare Operations and county and tribal agencies must pay the fees involved in helping clients obtain the required documentation. Costs associated with verification of U.S. citizenship and identity are eligible for 50% federal matching administrative funds.

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Transfer and Retention of Documentation

When transferring a case from one county to another or between counties, tribal agencies and MinnesotaCare Operations, the transferring agency is responsible for assuring that any paper copies of citizenship and identity verification are in the transferred case file.

Agencies are responsible for maintaining verification of citizenship and identity in the case file. Unless the SSA data match verifies citizenship and identity, retain a paper copy of citizenship and identity verification in the case file.

Follow the current retention schedule for destroying case records when cases become inactive. If a client who previously provided verification of citizenship and identity reapplies after the case record has been destroyed, the client must cooperate with providing citizenship and identity verification again.

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Related Topics

For further information, see:

Sources of Citizenship and Identity Verification.

Process for Documentation of U.S. Citizenship and Identity.

Cooperation with Documentation Requirements.

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