11.05.05 Sources of Citizenship and Identity Verification

*** The Health Care Programs Manual (HCPM) has been replaced by the Minnesota Health Care Programs Eligibility Policy Manual (EPM) as of June 1, 2016.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. ***

Sources of Citizenship and Identity Verification

Verification of U.S. citizenship and identity may be obtained on the client’s behalf by the processing agency or may be submitted by the client directly. There are various resources available to the processing agency to assist clients with obtaining documentation. When the processing agency is unable to assist clients with obtaining verification of citizenship and identity, clients must provide paper copies of citizenship and/or identity verifications. The various types of acceptable paper citizenship and identity verifications are listed in this section.

This section provides information about sources and types of citizenship documentation in the order of preferred usage.

Use the following sources to obtain verification of citizenship and identity for clients who have not previously provided documentation. These sources are listed in order of preferred usage. The applicant may also provide paper documentation of citizenship and identity at any time. Of the agency resources, only the SSA data match is a level one verification that verifies both citizenship and identity.

Verify citizenship and identity for MA applicants by submitting a Social Security Administration (SSA) data match request through MAXIS. The SSA data match is an electronic interface between DHS and SSA that verifies both citizenship and identity. Additional documentation is not required.

The SSA data match cannot be initiated for clients requesting only MinnesotaCare or MFPP. However, if an SSA data match previously verified U.S. citizenship, the citizenship verification requirement has been satisfied.

Follow the instructions in POLI/TEMP TE02.08.166 to submit an SSA data match request.

n MA applicants and enrollees who are required to verify U.S. citizenship and who have not previously provided verification.

n MA applicants and enrollees who provide incomplete citizenship verification. For example, an applicant or enrollee submits a birth certificate and does not submit verification of identity.

Lucinda applies for MA for herself and her 4-year-old child, Michael. She submits a copy of her birth certificate with her application, but does not submit documentation of identity. She does not submit documentation of citizenship for Michael.

Submit an SSA Data Match request to verify citizenship and identity for both Lucinda and Michael.

n People who are enrolled in MinnesotaCare for adults without children who become eligible for MA.

Mary is a U.S. citizen and is enrolled in MinnesotaCare for adults without children. On September 1 she provides proof that she is pregnant and requests MA. She must submit verification of citizenship and identity.

Change Mary’s eligibility to MA back to the first of the month of conception or up to three months prior to her eligibility begin date, whichever is later. Submit an SSA data match to verify her citizenship and identity.

n Ineligible MA applicants who have requested a determination for MinnesotaCare families with children or MFPP:

m Submit the SSA Data Match request prior to determining eligibility for other programs and prior to transferring the case for another program determination.

m If the application is transferred to another agency for processing, indicate that the SSA data match request was submitted on the Inter-Agency Case Transfer form (DHS-3195).

m Prior to determining eligibility for MinnesotaCare or MFPP, check MAXIS to determine if the SSA data match request successfully verified citizenship.

Lila applies for health care for herself and her four-year-old daughter, Rose, at her local county agency. She indicates on the application that they are both U.S. citizens, but does not submit proof of citizenship with the application. They are not eligible for MA due to excess income. Their county does not process MinnesotaCare cases, so the case is transferred to the State MinnesotaCare Operations.

Prior to transferring the case to MinnesotaCare Operations, submit an SSA Data Match request. Indicate that an SSA data match request was submitted on the Inter-Agency Case Transfer form and instruct the MinnesotaCare worker to check MAXIS for the response.

Occasionally, the SSA data match does not verify citizenship (in other words, there is not match or there are discrepancies between the records that prevent a match). When the SSA Data Match does not verify citizenship, follow these steps to request verification of citizenship and identity from the client:

1. Send the enrollee the Request for Proof of Citizenship and Identity (DHS-6230) and enclose the Citizenship and Identity Proofs (DHS-6231). The Request for Proof of Citizenship and Identity informs the enrollee that the agency was unable to verify his or her U.S. citizenship through the SSA data match and lists three options for resolving the inconsistency. Check the appropriate boxes for follow up when sending the request.

2. Request a response within two months from the date of the request. Check the appropriate boxes for follow-up.

3. If the enrollee contacts the agency and reports that his or her SSN, date of birth, or name is incorrect or has changed, update MAXIS with new information. Submit a new SSA Data Match request.

Note: If the second SSA Data Match request does not verify citizenship, mail a second Request for Proof of Citizenship and Identity (DHS-6230) to request alternate verification of U.S. citizenship.

4. If the enrollee confirms the identifying information on MAXIS is correct, instruct the enrollee to contact the SSA to resolve the issue and notify worker of the changes, or provide alternate verification of U.S. citizenship. Submit a new SSA Data Match request if the enrollee reports he or she has resolved the issues with SSA.

5. Send a second Request for Proof of Citizenship and Identity (DHS-6230) if the enrollee does not submit verification of U.S. citizenship by the end of the two-month period. Indicate that proof of citizenship must be submitted (check the third box) and enclose the Citizenship and Identity Proofs (DHS-6231). Request a response within 30 days from the date of the second request.

6. Close MA with ten-day notice on the 31st day if the enrollee does not respond to the second request or otherwise fails to cooperate.

7. Enter case notes with detailed information about citizenship and identity documentation or exemption from documentation for all cases. 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.

Note: The Minnesota Health Care Programs (MHCP) Worker Checklist - Proof of U.S. Citizenship and Identity (DHS-4842) is no longer required.

Do not deny or close eligibility when an enrollee is cooperating with obtaining verification of U.S. citizenship, or while the agency is in the process of obtaining documents. Assist enrollees if they ask for help or are having difficulty obtaining verification.

EVVE is a web-based system that requests birth records for the purpose of verifying U.S. citizenship for Minnesota and other participating states. 19 States are currently participating in the EVVE program. EVVE does not verify identity.

Submit an EVVE request to verify U.S. citizenship if citizenship is not verified through another source.

n Require clients to sign the Authorization to Request Birth Records (DHS-4841). This form authorizes the agency to request birth record documents from the state where the client was born.

n Follow the worker instructions in SIR > MMIS > Documentation > EVVE to submit an EVVE request and to determine which states are currently participating in EVVE.

Birth records obtained through Minnesota Birth Records Application process do not verify identity. Separate documentation of identity is required.

For clients who were born in another state, birth records can be obtained directly from the state of birth:

n Require clients to sign the Authorization to Request Birth Records (DHS-4841). This form authorizes the agency to request birth record documents from the state in which the clients were born.

Note: If another state requests that a different form be used to request citizenship verification, follow that state’s requirements.

Birth records obtained from the state of birth do not verify identity. Separate verification of identity is required.

Suzanne and her two children recently moved to Minnesota from Missouri. Suzanne is applying for MinnesotaCare for all household members. Suzanne has been told it will take several months to obtain their birth certificates from Missouri. She has no other documents showing where they were born. Suzanne submits documentation of identity for herself and her two children.

Suzanne signs the DHS-4841, giving permission to contact the Missouri vital records office to obtain their birth certificates.

Send a request to Missouri for the birth certificates. Approve health care coverage if all other eligibility criteria are met. Track for receipt of their birth records.

Clients who were previously enrolled in MA in another state were required to verify citizenship as a condition of eligibility for MA. As such, verification of citizenship and identity may be requested from the state where the client was previously enrolled in MA, if it is not available through other sources.

To request verification of citizenship and identity from the state where the client was previously enrolled in MA:

n Request a signed release from the client or the client may sign the Minnesota Department of Human Services General Authorization for Release of Information (DHS-2243A) to allow the agency to contact the other state.

n Once the release is signed, contact the state human services agency where the client previously resided to determine if citizenship and identity has been documented there. Contact information for states’ human services agencies can be found on the internet.

n Request copies and indicate in case notes if the previous state has verified citizenship and identity. Track for the return of the documentation.

Many clients submit verification of U.S. citizenship with their health care application. To determine whether the verification submitted is complete, refer to the Hierarchy of Citizenship Verification and Identity Documentation sections for a list of acceptable citizenship and identity documents. If complete verifications are received, the citizenship verification requirement has been satisfied and further verification is not required.

Submit an SSA data match request for MA applicants who submit incomplete verification of citizenship with their application. If the SSA data match is unable to verify citizenship, follow the ”r;Steps to Take When the SSA Data Match Fails to Verify Citizenship.”

MinnesotaCare for families with children and MFPP enrollees must provide paper verification of citizenship and identity. Assist clients with obtaining documentation from one of the alternate sources listed above, if the client does not have verification readily available.

Follow the hierarchy of citizenship verification for enrollees whose citizenship and identity cannot be verified through the SSA data match or other sources.

Clients do not have to appear in person to submit verification of U.S. citizenship and identity. They may submit copies of documentation with their application in person, by fax, or by mail.

There are four levels within the hierarchy for verification of U.S. citizenship, from Level 1 (most preferred) to Level 4 (least preferred). A separate list of documents applies to verification of identity.

l Start with Level 1, but do not delay moving to the next level if verification from higher levels is not available.

l If verification from higher levels of the hierarchy is not immediately available but the client is otherwise eligible, accept a lower level of verification, such as affidavits.

l Clients remain eligible as long as they cooperate with obtaining higher-level documents. However, if no higher-level verification can be obtained, eligibility must continue based on the level of documentation the client is able to provide.

People who present verification of U.S. citizenship from Level 1 do not have to provide separate verification of their identity.

Note: People who were born outside the U.S. and were not U.S. citizens at birth must provide Level 1 verification of U.S. citizenship to meet this requirement.

Note: Do not accept an expired U.S. passport issued to a person born in Puerto Rico as documentation of U.S citizenship.

n Tribal enrollment or membership card or certification of degree of Indian blood issued by a federally recognized Indian tribe.

People who do not have Level 1 verification may provide a document from Level 2 as verification of U.S. citizenship.

The following Level 2 documents verify citizenship and must be provided with verification of identity:

n U.S. public birth record (birth certificate). Must be recorded within five years of birth and show birth in one of the 50 states; District of Columbia; American Samoa; Swains Island; Puerto Rico; U.S. Virgin Islands, or Northern Mariana Island.

Note: Puerto Rican birth certificates issued prior to July 1, 2010 may not be used to verify citizenship for applicants whose MA, MinnesotaCare, or MFPP eligibility is determined for the first time on or after November 1, 2010.

n Final adoption decree or letter from adoption agency showing U.S. place of birth.

n Final adoption decree or a letter from the adoption agency for noncitizen adopted children who derive U.S. citizenship from parents. Noncitizen adopted children automatically derive U.S. citizenship from their parents if they meet all of the following on or after February 27, 2001:

People may provide Level 3 documents if they do not have U.S. citizenship verification from Levels 1 or 2. The following Level 3 proofs of citizenship must be submitted with identity verification:

n Extract of hospital record on hospital letterhead created or insurance record created at least 5 years before application/renewal. For children under age 16, record must have been created near time of birth.

n Official religious record recorded within 3 months of birth showing U.S. place of birth.

People may provide one of the following Level 4 verifications to prove their U.S. citizenship when they are not able to obtain documents from Levels 1-3. Clients remain eligible as long as they cooperate with obtaining a higher-level document. Clients must also provide verification of their identity.

n One of the following that shows U.S. place of birth and was created at least five years before application/renewal. For children under age 16, record must have been created near time of birth:

m Bureau of Indian Affairs census record of the Navajo Indians or Roll of Alaska Natives.

One form of Level 4 documentation is affidavits. Request affidavits in circumstances when a higher level of verification is not immediately available and when no other form of verification can be obtained. In order for affidavits to be acceptable verification of U.S. citizenship, all of the following must be completed:

n The client must complete the Proof of U.S. Citizenship - Statement by Applicant/Enrollee form (DHS-4843A), explaining why documentary evidence of U.S. citizenship does not exist.

n Require the client to sign the Authorization to Request Birth Records (DHS-4841). This authorizes the agency to request a higher level of verification from third parties.

n Obtain additional affidavits from at least two other people who are U.S. citizens and who have personal knowledge of the events establishing the client’s claim of citizenship. Use the Proof of U.S. Citizenship - Statement by Friend or Family Member form for these affidavits (DHS-4843B).

m At least one of the individuals making the affidavit must not be related to the client.

m These individuals must provide proof of their own U.S. citizenship and identity. A statement in the affidavit is sufficient proof.

m These individuals must state why documentary evidence of the client’s U.S. citizenship does not exist or cannot be obtained if they have knowledge of this information.

n All of the affidavits must be signed under penalty of perjury. Do not require notarization of the affidavits.

n Do not accept an affidavit to document identity if affidavits are used to document citizenship.

Verification of identity is required if clients provide citizenship verification from Levels 2 - 4. If U.S. citizenship is verified with a Level 1 document, the verification of identity is not required.

As verification of identity, individuals age 16 or older must provide a document from this list:

n U.S. passport, PASS card, Certificate of Naturalization or Certificate of Citizenship.

n State driver’s license or government issued ID card with picture or other identifying information.

n Cross match with federal or state government, public assistance, law enforcement, or correction’s agency data system. Must be a program such as food stamps that requires certification of identity.

n For persons unable to leave a facility due to illness or disability, an affidavit attesting to the person’s identity signed by the facility director or administrator.

n Where no other documentation is available, three or more corroborating documents such as marriage license, divorce decree, death certificate, high school diploma, FED, employer ID card or property deed/title. These can only be used if applicant submitted 2nd or 3rd level, citizenship documentation.

n For children under age 18, if a document from one of the preceding groups is not available, an affidavit signed under penalty of perjury by parent, guardian or caretaker relative is acceptable.

Individuals under age 16 may provide a document from the list above, or any of the following documents:

n If a document from one of the preceding groups is not available, an affidavit signed under penalty of perjury by parent, guardian or caretaker relative is acceptable.

For more information about U.S. citizenship and identity documentation requirements, see:

Chapter 11 - Citizenship and Immigration Status	Effective: January 1, 2012
11.05.05 - Sources of Citizenship and Identity Verification	Archived: June 1, 2016 (Previous Versions)