Family MO HealthNet (MAGI) Manual

1805.000.05 Reasonable Opportunity (RO)

IM-22 April 11, 2024; IM-108 July 19, 2022; IM-146 November 27, 2017IM-71 June 15, 2017IM-43 May 11, 2017IM-13 February 1, 2017

42 CFR 435.956 states Family Support Division (FSD) must provide participants a reasonable opportunity to provide documentation of citizenship, national, or qualified immigrant status, (hereafter, referred to as “status”).  The RO is a period of time participants are given to provide documentation of status, if status cannot be verified at application or before approval. 

The RO period is 90 days, plus 5 days to allow time for the participant to receive notices by mail, making the total RO period 95 days.

See manual sections 1805.020.05.05 Documents to Verify Citizenship and/or 1805.020.10 Qualified Immigrant for information describing documentation of status.

Allow Reasonable Opportunity

Allow RO when:

The participant is requesting MO HealthNet (MHN) benefits, status cannot be verified with information available to FSD, and the participant has submitted a signed MHN application OR signed a Citizen/National/Eligible Immigrant Attestation (IM-40) form to declare his or her status.

  • Signed MHN Application Form

Note:  As phone applications are recorded, these are considered signed applications.

    • Allow declarations of status from previous applications, unless questionable.

Example:  Rayna reports a change and requests coverage by phone for her son, Lane.  Lane is already included in her household, but she’s never requested coverage for him before.  A review of Rayna’s case record reveals when she applied 2 years ago for herself, Lane was on the application and Rayna declared he was a citizen at the time, but didn’t request coverage for him.  FSD sends her a Request for Information to provide documentation of his citizenship, and approves his coverage with an RO period.

Example:  Rayna completes a change report to request coverage for her new spouse, Kyle.  Kyle was not included on the original MHN application Rayna filed.  FSD sends Rayna a Request for Information along with form IM-40 Citizen/Eligible Immigrant Attestation Form.  The Request for Information explains that she can provide proof of Kyle’s citizenship by providing an item listed on the request OR she can complete the form to declare his citizenship and possibly qualify for 95 days to obtain documentation of Kyle’s citizenship.  She fails to respond to the Request for Information and FSD rejects her request for Kyle’s coverage.

Proof of Identity

If proof of identity is needed to verify citizenship, allow an RO period for the participant to provide the proof of identity.

Example: Becky requests coverage for herself and provides a copy of her birth certificate.  As a birth certificate is not a document that verifies both citizenship and identity, FSD sends a request for proof of identity and grants an RO period for Becky to provide the proof.

Request Information

Send a Request for Information to participants who must provide verification of status.  On the request, detail the information that can be provided to verify this factor.  System generated Requests for Information include this information automatically.


After sending a Request for Information to request verification of status, immediately approve coverage for participants if:

  • The participant has declared his/her citizenship/immigrant status on a signed application or IM-40 Citizen/Eligible Immigrant Attestation form, and
  • All other eligibility factors are met.

Do not wait for the Request for Information to expire.  Begin the RO period on the date of approval for MHN benefits, when possible, or the next day if an overnight batch process is required to generate the request systematically.

For households in which at least one member was allowed RO to verify status, include the following statement on the Approval Notice:

Proof of [Choose one of the following] Citizenship/national/qualified immigration status was requested for ___________and was not provided.  _________was approved for MO HealthNet, but may lose coverage if his/her [choose one of the following] proof of citizenship/national/qualified immigration status is not provided within 95 days of this letter.  Contact Family Support Division if you have a delay in obtaining this verification.

Prior Quarter (PQ)

Allow RO for PQ months.  If the citizenship or qualified immigrant status is not verified at application, approve the PQ with RO when the ongoing benefit is approved.

RO Extensions

RO ends the 95th day after approval, or when the participant provides acceptable documentation to verify status. 

If the participant indicates difficulty providing documentation by the end of the RO, but demonstrates a good faith effort to provide it, extend the RO period by 90 days on an as-needed basis.  Verify the good faith effort and document details including any decision to extend the RO.

Example:  Harley’s RO period expires on 10/31.  On 10/20, Harley mails FSD a copy of a letter he received from the state of California.  It states they have received his request for a copy of his birth certificate, but will be unable to fulfill the request before 11/10.  Harley’s RO period is extended to 1/31.  On 11/17, Harley provides the documentation and his RO ends.


If the participant has not provided the requested documentation of status by the end of the RO and any extensions, send an Adverse Action notice and discontinue MHN coverage after it expires.

RO and 1805.070.00 Continuous Eligibility for Children (CEC)

When RO is granted, the continuous eligibility begin date for the child is made retroactive to the date benefits were first approved during the RO period if the individual’s U.S. citizenship or satisfactory immigration status is ultimately verified.

Continuous eligibility is not in effect until verification has been provided. If verification is not provided during the RO timeframe, eligibility can be ended.