2006 Memorandums
IM-66      06/23/06


MANUAL REVISION # SECTIONS 0110.020.00, 0405.030.00, 0860.005.30, 0865.010.20, 0905.010.30, 0905.010.30.25, 0920.010.20, 0925.010.20, 1010.000.00, 1305.010.00


Section 6036 of the Deficit Reduction Act of 2005 amended section 1903 of the Social Security Act requiring states to obtain satisfactory documentation of citizenship in order to receive Medicaid benefits. Effective July 1, 2006, states must obtain documents establishing identity and citizenship for new applicants and recipients for all categories of Medicaid, except for the Presumptive Eligibility for Children and the Presumptive Eligibility for Pregnant Women (TEMP) programs. This change becomes effective with all applications dated July 1, 2006 or later and all reinvestigations completed beginning the month of July 2006.

New applicants must verify both of these factors prior to being approved for benefits. Citizenship and identity will be verified for current recipients at the next reinvestigation. DO NOT delay entry of the reinvestigation for documentation of citizenship and identity. These recipients must be allowed a “reasonable opportunity period” to provide documentation of these factors. System changes have been developed that will allow the worker to update the reinvestigation date for these cases while entering a pending code for citizenship and identity verification; these changes will be discussed below. Citizenship and identity are not required to be verified in person. However, staff must view and copy acceptable forms of verification (original or certified copy of the original). It is important for staff to work closely with individuals and provide assistance in obtaining this information to ensure timely benefit delivery and to avoid individuals losing coverage. Once citizenship and identity have been verified, the requirement has been met and is not required to be verified again at subsequent applications/reinvestigations.


Subsection (i)(23) of Section 1903 of the Social Security Act requires that satisfactory documentary evidence of citizenship and identity must be obtained for any individual declaring to be a citizen or national of the United States. Some forms of documentation serve to verify both identity and citizenship; others serve to verify citizenship only and require additional documentation to verify identity. Documents which verify both citizenship and identity are considered the most reliable and preferred forms of documentation. Use these documents, when available, to establish both citizenship and identity. When these documents are not available and cannot be readily obtained, obtain two forms of documentation, one to verify citizenship and the other to verify identity.

All documents provided must be either originals or copies certified by the issuing agency. The eligibility specialist is required to keep a copy that has been made of the original document or certified copy in the case record so that it may be available for compliance audits. A copy of the original document or certified copy is required to be kept in the record, however it is important to note that it is not a requirement that the applicant or recipient come in to the office to complete the application or reinvestigation. Documents may be accepted by mail.



Note: When using a document from this list to verify citizenship, a second document must be obtained to verify identity.


Section 1903(x) provides that identity must be established. When documents verifying both citizenship and identity are not available, a document may be used to verify citizenship accompanied by a second document that verifies identity. The following list gives examples of documents accepted as verification of identity:

Verification of identity for children is also a requirement. States have been allowed the flexibility of utilizing an affidavit to verify the identity of children under age 16 for whom Medicaid benefits are being requested. Parents/related caretakers/legal guardians can sign the application or reinvestigation form attesting to the identity of the children for which they are applying. Changes are being made to the application and reinvestigation forms to add the affidavit to the forms. For all other individuals making application for children, including children applying as their own caretaker, documentation of identity must be obtained. The following provides additional sources of documentation of identity for children under age 16:

Questions regarding acceptability of forms of documentation not listed above should be submitted to the Income Maintenance Program and Policy Unit. Additionally, if an individual is unable to obtain one or more of the above documents, submit specific case details, through supervisory channels, to Program and Policy for clarification and assistance. Do not reject or terminate coverage in special case situations or when uncertain of documentation provided without receiving further clarification from Program and Policy.


States have been given the option to utilize data matches with other programs which verify citizenship and identity as part of their program requirements. For example, a match of Medicaid applicants or recipients to the State Data Exchange (SDX) would satisfy the documentation requirement of this provision with respect to SSI recipients. The information on the SDX reflects both alien status and citizenship status for every individual for whom the information is available. If an applicant or recipient claims to be a citizen or national and receives SSI benefits, citizenship is verified if receipt of SSI is verified through SDX. Verification of receipt of SSI and citizenship is a considered documentation of both citizenship and identity. No further documentation is necessary.


Citizenship and identity are not required to be verified to add children as NEWBORNS (LOC “G”) as these children are deemed to have applied for and been found eligible to receive Medicaid benefits as a result of their mothers being active recipients at the time of birth.


At the time of application or reinvestigation, the applicant/recipient must be given a reasonable time period to present documents establishing U.S. Citizenship or Nationality. The time period allowed for an individual is based on whether s/he is a new applicant or a current recipient. It is important that staff work closely with applicants and recipients in obtaining the necessary information to verify citizenship and identity. Assist clients who are having difficulty providing acceptable documentation and contact Program and Policy for further assistance if necessary.


An applicant must be eligible based on all eligibility factors, including verification of citizenship and identity, in order to be approved for Medicaid. It is required that the Eligibility Specialist send two requests for information to the applicant requesting verification of identity and citizenship. When communicating with the applicant during the application process, provide sources of acceptable documentation and assist when necessary in obtaining the information. DO NOT reject the application prior to the due date if citizenship documentation has not been provided. If an applicant is making a good faith effort to obtain documentation and provides an explanation to the Eligibility Specialist as to why the documentation will be delayed, do not reject the application.

In circumstances where the documentation has been provided for some of the applicants in the household, but not all, do not delay processing of the application for those individuals for whom documentation has been provided. Hold the application until the due date to allow for documentation for all applicants to be provided. On the due date, approve the application for those who have provided documentation and make those individuals for whom documentation has not been provided a LOC Z. Individuals for whom documentation was not provided can be added at a later time when documentation is received. If two requests for documentation have been sent and the applicant does not respond or give any indication that s/he is making an effort to obtain the required documentation, reject the application on the due date. Fair hearing rights apply.


Verification of citizenship and identity are required to be obtained at the next reinvestigation for current Medicaid recipients. Send a request for information to the recipient for citizenship and identity documentation. Work with recipients in an effort to obtain the necessary documentation by the reinvestigation due date. If they experience difficulty in obtaining the information, complete the review in the system and allow him/her a reasonable time period to present the required document(s). IMU5 changes have been developed to allow a recipient to continue to receive Medicaid while attempting to obtain the necessary documentation. A code has been created that will allow the Eligibility Specialist to update the reinvestigation date when all information, other than citizenship/identity, is re-verified. These system changes are discussed below.

If information provided verifies that the recipient continues to be eligible on all eligibility factors, other than citizenship/identity documentation, update the case data including the review date. Continue to work with recipients to obtain the requested documentation. A report will be sent to staff when an individual has a pending code for 90 days or more. The report will be sent at 90 days and every 90 days thereafter until the code is changed to reflect that citizenship/identity have been verified.


System changes will be in place effective July 1, 2006, to accommodate the new citizenship requirements. Continue to enter the alien code in Field 13H. Field 13H1 is being added to capture the verification code for individuals who claim to be citizens. Valid entries in this field are:

Entries in Field 13H1 will only be allowed when the citizenship/alien code “C” is entered in Field 13H. Valid entries for this field are based on whether the individual is an applicant or recipient:

Example: Mr. and Mrs. Webster apply for MA on 7/3/06. Mr. Webster provides all information needed to determine eligibility including citizenship and identity documentation on himself, but no documentation of citizenship and identity for his spouse. Worker determines Mr. Webster is eligible for MA non-spenddown coverage. When entering the approval, the worker enters Mr. Webster as a “T” LOC and enters a “Y” in field 13H1 to indicate citizenship and identity are verified. Identity and citizenship are not verified for Mrs. Webster, so the worker enters a “Z” LOC for Mrs. Webster and enters “N” in field 13H1 to indicate identity and citizenship are not verified.

Example: Ms. Allen is receiving MAF for herself and her two children ages 4 and 6. She and her children were born in Springfield, IL. Her MAF annual reinvestigation is due for the month of July, 2006. You receive her completed IM-1UA on 7/5/06. All information is verified except citizenship and identity. You send Ms. Allen a request for documentation of citizenship and identity for herself and two children. Ms. Allen contacts the office on 7/17/06 and explains that she has contacted the State of Illinois and that it will take 4-6 weeks to receive their birth certificates. She provides you all other information needed to determine continued eligibility, including identity. On 7/31/06, worker enters updated case information including review date in field 47. In field 13H1, “P” is entered for the client and for each child. On 8/15/06, the client provides the Eligibility Specialist the birth certificates for her and her children. A copy of the Birth Certificates is filed in the record. The Eligibility Specialist changes the code in Field 13H1 from “P” to “Y” for each individual.

A report will be sent to each county office showing the list of recipients who still have a pending verification code in the system after 90 days. Reports will continue to be sent every 90 days and individuals will continue to be reported until their status has been updated in the system. If citizenship documentation has been requested and the recipient has not provided documentation after 90 days, but is still attempting to obtain the necessary documentation, leave the pending code in the system and continue to attempt to verify citizenship/identity. For those individuals who do not show they are making a good faith effort to obtain documentation, the Eligibility Specialist may terminate coverage. An advance notice of adverse action (IM-80) is required to be sent prior to terminating coverage for failure to provide verification of citizenship and identity.



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