1805.020.05.05 Documents to Verify Citizenship

IM-31 May 28, 2024; IM-88 October 24, 2023; IM-110 July 17, 2020; IM-32 April 23, 2018; IM-147 November 27, 2017; IM-70 June 15, 2017; IM-94 December 28, 2016

42 CFR §435.407 and §436.407 describe the documents needed to verify citizenship and identity.

As of January 20, 2017, a photocopy, facsimile, scanned or other copy of a document must be accepted to the same extent as an original document under this section, unless information on the copy submitted is inconsistent with other information available to the agency or the agency otherwise has reason to question the validity of, or the information in, the document.

Citizenship and Identity Documentation

Acceptable forms of documentation that verify both citizenship and identity are:

U.S. passport
Certificate of Naturalization (N-550 or N-570)
Certificate of Citizenship (N-560 or N-561) — issued to individuals who derive citizenship through a parent (see Child Citizenship Act of 2000 below)
A valid State-issued driver’s license as follows:

Missouri Driver’s License Inquiry (MODL) system where the Detail Identification Inquiry screen (upper right side) indicates that the person is a verified U.S. citizen.

Note: MODL cannot be used to verify relationships, as it does not capture coding details for why a name has been changed.

For driver’s licenses/state ID’s from states other than Missouri, the license is proof of citizenship and identity when the state issuing the license requires:
- proof of U.S. citizenship before issuance of such license, or
- obtains and verifies the Social Security Number (SSN) from the applicant

Staff will need to check with the issuing state to verify the state’s process.

A data match with the Social Security Administration (SSA). Using the State Verification and Exchange System (SVES), SSA will compare an individual’s name, SSN, and citizenship declaration with data in its Master File of SSN Holders.

Note: A verified SSN is NOT verification of citizenship. Citizenship may be verified through a Bendex, SDX or IIVE alien indicator. Refer to the CITIZENSHIP DOCUMENT ENTRY FOR APPLICATIONS guide in IM Resources for more information.

Note: Do NOT file IIVE screens in the case record.

Documentary evidence issued by a federally-recognized Indian Tribe identified in the Federal Register by the Bureau of Indian Affairs within the U.S. Department of the Interior, and including Tribes located in a State that has an international border, which:

Identifies the federally-recognized Indian Tribe that issued the document
Identifies the individual by name; and
Confirms the individual’s membership, enrollment, or affiliation with the Tribe

Note: The documents listed above may include, but are not limited to:

A Tribal enrollment card
American Indian Card ( I-872)
A Certificate of Degree of Indian Blood
A Tribal census document
Documents on Tribal letterhead, issued under the signature of the appropriate Tribal official, that meet the requirements of paragraph (a)(5)(i) of this section

Section 1903(x) of the Social Security Act states that individuals who are eligible for MO HealthNet or CHIP as “deemed newborns” are considered to have provided satisfactory documentation of citizenship and identity (by virtue of being born in the United States) and will not be required to further document citizenship or nationality at any subsequent MO HealthNet or CHIP eligibility determination or redetermination.

Note: In Missouri, LOC of “G” (newborn coverage) on the MXIX screen verifies this factor.

IBTH, if born in Missouri.

Note: Do NOT print IBTH screens or file in the case record

A data match with the Systematic Alien Verification for Entitlements (SAVE) system or any other process established by Department of Homeland Security (DHS) to verify that an individual is a natural born, naturalized or derived citizen

Note: MEDES verifies a participant’s citizenship and immigration status by:

1. - 1. Sending a request to the Hub (Federal Data Services Hub) to verify citizenship or immigration status.
    2. If additional verification is needed, the Hub will automatically submit additional data to SAVE requesting DHS verify the status of the case. No action is taken by staff to verify status.
    3. If citizenship cannot be established, staff must take appropriate action to gather citizenship and immigration documentation for the participant by following the steps outlined in the Verify Lawful Presence guide in IM Resources.

Citizenship Documentation

If one of the above forms is not available, you must obtain one of the following documents to verify citizenship and a second source to verify identity. The following documents may be used to verify citizenship for MO HealthNet programs:

A U.S. public birth certificate showing birth in one of the 50 States, the District of Columbia, Guam, American Samoa, Swain’s Island, Puerto Rico (if born on or after January 13, 1941), the Virgin Islands of the U.S. or the CNMI (if born after November 4, 1986, [CNMI local time]).

NOTE: Evidence of birth in Puerto Rico and the applicant’s statement that he or she was residing in the U.S., a U.S. possession, or Puerto Rico on January 13, 1941 is acceptable.

Certification of Birth (DS-1350)
Consular Report of Birth (FS-240)
Certificate of Birth Abroad (FS-545)
S. Citizen ID Card (I-197 or I-179)
Northern Marianas Identification (NMI) card (I-873)
Final adoption decree
Evidence of U.S. Civil Service employment before June 1, 1976
S. Military Record showing a U.S. place of birth
Hospital record on hospital letterhead

Note: For children under five, must be at or near time of birth.

Statement signed by physician or midwife present at time of birth
Medical (clinic, doctor, or hospital) records that created at least five years before application
Life or health insurance record showing a U.S. place of birth created at least five years prior to application
Official religious record recorded in the U.S. showing that the birth occurred in the U.S.
School records, including pre-school, Head Start and daycare, showing the child’s name and U.S. place of birth
Federal or state census record showing U.S. citizenship or a U.S. place of birth
S. State Vital Statistics official notification of birth registration
Institutional admission papers created at least five years prior to application date that includes a U.S. place of birth
If the applicant does not have one of the citizenship documents listed above, they may submit an affidavit signed by another individual under penalty of perjury who can reasonably attest to the applicant’s citizenship, and that contains the applicant’s name, date of birth, and place of U.S. birth. The affidavit does not have to be notarized.

Per the Child Citizenship Act of 2000 (Pub. L. 1006-295), consider a biological or adopted person born outside of the United States a citizen if the following conditions were met on or after February 27, 2001:

One of the person’s parents is a United States citizen (whether by birth or naturalization; verified by the standards of citizenship verification listed in this section) and
The person was legally residing in the United States, in the custody of a citizen parent, while under the age of 18

Note: A participant with documentation verifying a legal status other than citizenship, such as Lawful Permanent Resident, may meet the conditions of this act. Despite documentation that indicates a status other than citizenship, if evidence suggests a parent of a participant is a citizen, explore citizenship eligibility for the participant under the conditions of the Child Citizenship Act of 2000.

Participants can provide a Certificate of U.S. Citizenship as proof that these conditions have been met. However, do not require participants to obtain or provide a Certificate of U.S. Citizenship if it can be proven by other means that the participant meets the conditions of the Child Citizenship Act of 2000.

Record details of verification used to prove how each condition was met.

Identity Documentation

FSD must accept the following as proof of identity for MO HealthNet cases, provided such document has a photograph or other identifying information sufficient to establish identity, including, but not limited to, name, age, sex, race, height, weight, eye color, or address:

Driver’s license issued by the State or U.S. Territory
School identification card
S. military card or draft card with photograph
Identification card issued by the Federal, State, or Local government
Military dependent’s identification card
S. Coast Guard Merchant Mariner card
For children under age 19, a clinic, doctor, hospital, or school record, including preschool or day care records
For children newborn up to but not including age 16, identity can be verified by the signature of a parent/related caretaker/legal guardian on the application or reinvestigation forms. This signature is considered an affidavit to the child’s identity.

Note: Do not request verification of identity again when the child turns 16 years old as long as there is continuous eligibility for that child and there is the prior affidavit signature of the parent/related caretaker/legal guardian.

A finding of identity from the following FSD programs as defined in section 1902(e)(13)(F) of the Social Security Act:

- Supplemental Nutrition Assistance Program (SNAP)
- Temporary Assistance program
- Any MO HealthNet program

A finding of identity from specific public agencies and Indian Tribes and Tribal organizations such as:

- The Head Start Act
- The Richard B. Russell National School Lunch Act
- The Child Nutrition Act of 1966
- The Child Care and Development Block Grant Act of 1990
- The Stewart B. McKinney Homeless Assistance Act
- The United States Housing Act of 1937
- The Native American Housing Assistance and Self-Determination Act of 1996
- The Indian Health Service, an Indian Tribe, Tribal Organization, or Urban Indian Organization

Two other documents containing consistent information that corroborates an applicant’s identity. Such documents include, but are not limited to:

- employer identification cards
- high school, high school equivalency and college diplomas
- marriage certificates
- divorce decrees
- property deeds or titles

FSD may accept as proof of identity for MO HealthNet programs a finding of identity from a federal agency or another state agency, including but not limited to, a law enforcement, internal revenue or tax bureau, or corrections agency, if the agency has verified and certified the identity of the individual.
If the applicant does not have any documents specified above, the agency must accept an affidavit signed, under penalty of perjury, by a person other than the applicant who can reasonably attest to the applicant’s identity. Such statements must contain the applicant’s name and other identifying information establishing identity including but not limited to, name, age, sex, race, height, weight, eye color, or address. The affidavit does not have to be notarized.

FSD may rely, without further documentation of citizenship or identity, on a verification of citizenship made by a federal agency or another state agency, if such verification was done on or after July 1, 2006.

FSD must provide assistance to individuals who need assistance in securing satisfactory documentary evidence of citizenship and/or identity in a timely manner. If the individual is unable to obtain documentation listed above for either citizenship or identity, contact the MHN Program and Policy Unit for further assistance.