Medical Assistance

2.1.2.5 Social Security Number

The Minnesota Department of Human Services (DHS) uses Social Security Numbers (SSNs) to identify applicants and enrollees and to administer Minnesota Health Care Programs (MHCP). DHS matches SSNs against records in electronic data sources to identify and verify household income and size based on the most recent tax return filed by the household tax filer.

Each person requesting Medical Assistance (MA) must provide their SSN as a condition of eligibility unless they meet an exception. People who do not have SSNs and do not meet an exception must apply for an SSN. The following are exceptions:

An applicant who refuses to obtain an SSN because of a well-established religious objection
A noncitizen who is not eligible to receive an SSN or does not have one and may only be issued one for a valid non-work reason
People applying for or receiving Emergency Medical Assistance (EMA), CHIP funded MA for pregnant people or MA for people receiving services from the Center for Victims of Torture (CVT)
A child eligible for MA as an auto newborn
A child receiving Northstar Title IV-E Adoption Assistance
A child receiving Title IV-E or non-Title IV-E adoption assistance under the Interstate Compact on Adoption and Medical Assistance (ICAMA)
Refugees applying for or receiving Refugee Medical Assistance (RMA)

An agency may request but cannot require someone who is not applying for coverage to provide an SSN. If the agency requests the SSN of a non-applicant, the disclosure must:

be voluntary,
only be used to determine an applicant’s eligibility for a MHCP or for a purpose directly connected to administration of the State Plan, and
include clear information on how the SSN will be used and notice to the application filer that it is voluntary.

Pre- Eligibility Verification

If an applicant has an SSN , it must be provided prior to the MA eligibility determination. If an applicant cannot recall their SSN or if an SSN has not been issued for the applicant, and the person does not meet an exception, the county, tribal or state servicing agency must assist the applicant in:

completing an application for an SSN, if an SSN has not been issued for the applicant, or
contacting the SSA to confirm the applicant’s SSN if one has already been issued

If an applicant must apply for an SSN, proof that the person applied for an SSN is required prior to the MA eligibility determination. The proof of application is acceptable for the MA eligibility approval until the person receives the SSN. Once the SSN is received the individual must provide it to the agency. The agency must verify the newly issued number electronically.

Verifying Exceptions to Having an SSN

Certain exceptions from the requirement to have or apply for an SSN must be verified prior to the MA eligibility determination.

Well-established religious objection

A letter or other verification from a church leader that the religion is a recognized sect of division that is conscientiously opposed to applying for an SSN
Proof of filing for a waiver with the IRS using form 4029

Noncitizen unable to attain an SSN for a reason other than a valid non-work reason

No further proof is needed if the person does not have employment authorization or their status does not permit them to work in the United States
A letter from the SSA or other official that the person is not eligible for an SSN except for a valid non-work reason

Other exceptions from the requirement to have or apply for an SSN do not require proof.

Post Eligibility Verification

SSNs must be electronically verified with the Social Security Administration (SSA).

Eligibility cannot be delayed for an otherwise eligible applicant pending the electronic verification of an SSN if one is provided at application or when newly obtained by an enrollee. A notice must be sent to the person to inform them that they have 95 days from the date of the notice to provide proof of their SSN or to resolve any clerical discrepancies preventing electronic verification.

The 95-day period can be extended if the MA enrollee is demonstrating a good faith effort to resolve the discrepancy preventing electronic verification. Enrollees who need more time to resolve the SSN discrepancy must receive a notice that tells them the new due date. There is no limit to the number of times the reasonable opportunity period can be extended for the MA enrollee to resolve the SSN discrepancy. MA eligibility and coverage ends with 10- day advance notice if the enrollee fails to resolve the SSN discrepancy by the end of the reasonable opportunity period or any extension.

During the reasonable opportunity period, the county, tribal or state servicing agency must continue efforts to verify an applicant’s SSN. This includes correcting errant demographic data, re-running electronic sources and checking case records and files for prior instances of successful electronic verification. The agency must assist the applicant in resolving discrepancies in the case file that are preventing successful verification. The agency must document efforts to verify an applicant’s SSN during the reasonable opportunity period in the case record.

Electronic verification is ultimately required to verify a person’s SSN.

A person who applies for health care coverage, whose SSN was not previously verified, must be given a new reasonable opportunity period to resolve the SSN discrepancy.

Legal Citations

Code of Federal Regulations, title 20, section 422.104

Code of Federal Regulations, title 42, section 435.907

Code of Federal Regulations, title 42, section 435.910

Code of Federal Regulations, title 42, section 435.948

Code of Federal Regulations, title 42, section 435.952

Code of Federal Regulations, title 42, section 435.956

Code of Federal Regulations, title 42, section 457.340