MEMORANDUM

DISCUSSION:

Effective immediately, approve all MO HealthNet applicants who are otherwise eligible for benefits but have not provided documentation of citizenship and allow a reasonable time period to provide documentation of citizenship or national status. A reasonable opportunity is defined as 90 days from the date of approval. This change is required by Section 211 of the Children’s Health Insurance Program Reauthorization Act (CHIPRA) signed February 4, 2009, which amended section 1903(x) of the Social Security Act. The law allows an individual declaring to be a citizen or national of the United States who is required to present documentary evidence of citizenship or nationality a reasonable opportunity to present the documentation.

When an application for MO HealthNet is received without documentation of citizenship, provide the applicant with a Request for Information (IM-31A or FA325) for the necessary documentation. Once verification of all other eligibility factors is received, approve the eligible applicant and set a priority or reminder to follow up with the participant in 90 days. If documentation of citizenship or national status is not provided within 90 days, and the participant is not making a reasonable effort to provide documentation, action must be taken to remove the participant from MO HealthNet coverage.

NOTE: Documentation of citizenship includes proof of identity. Therefore, the application may be approved pending documentation of citizenship even when proof of identity has not been provided.

Legacy cases

When approving an applicant that meets all other eligibility factors other than documentation of citizenship, take the following actions:

• Enter a "P" in field 13H1 of IMU5. Programming changes have been made to allow approval when a "P" code is entered on an application.;
• Set a priority in field 18 to check on citizenship documentation within 90 days from the date of approval, and
• Follow up with the participant in 90 days.

If documentation has not been provided within 90 days, provide the participant an IM-31A allowing 10 days to provide verification.  If the participant fails to respond within 10 days:

• send an Adverse Action Notice (IM-80) to discontinue MO HealthNet coverage for all members for whom citizenship documentation has not been provided, and
• Once the Adverse Action Notice (IM-80) expires, discontinue coverage for all participants for whom documentation of citizenship has not been provided.

If the participant responds, but does not have citizenship documentation:

• determine whether the participant is making a good faith effort to provide documentation. 
• If the participant is making a good faith effort to provide documentation, set a new priority in field 18 of IMU5 to follow up in another 90 days.
• If the participant is not making a good faith effort to provide documentation, send an Adverse Action Notice (IM-80) to discontinue MO HealthNet coverage for all members for whom citizenship documentation has not been provided, and
• Once the Adverse Action Notice (IM-80) expires, discontinue coverage for all participants for whom documentation of citizenship has not been provided.

EXAMPLE: Ms. Williams, age 49, did not have documentation of citizenship with her when she applied for MO HealthNet for the Aged, Blind, and Disabled (MHABD) on 7-15-09. The eligibility specialist provided Ms. Williams a Request for Information asking for documentation. On 8-10-09, the Medical Review Team determined Ms. Williams is permanently and totally disabled. Ms. Williams now meets all eligibility requirements for MHABD except for documentation of citizenship. The eligibility specialist approves her application and enters "P" in field 13H1 of IMU5. A priority is set in field 18 to follow up on citizenship documentation in November.

Ms. Williams fails to provide documentation of citizenship by November.
The eligibility specialist sends Ms. Williams a Request for Information to provide documentation of citizenship within 10 days. Ms. Williams fails to respond within 10 days. The eligibility specialist sends Ms. Williams an Adverse Action Notice (IM-80) to close her MHABD case. After no response, the eligibility specialist takes action to close Ms. Williams' case when the Adverse Action Notice (IM-80) expires.

EXAMPLE: Although Mrs. Portico, age 58, had a certified copy of her birth certificate from the State of Indiana when she applied for MHABD on 7-27-09, she did not have proof of identity, which is a part of citizenship documentation. The birth certificate is in Mrs. Portico's maiden name of Williams, and her current driver's license is in her married name of Portico. The eligibility specialist provided Mrs. Portico a Request for Information asking for documentation needed for identity. On 9-22-09, the Medical Review Team determined Mrs. Portico is permanently and totally disabled. Mrs. Portico now meets all other eligibility requirements, and her application is approved. The eligibility specialist enters "P" in field 13H1 of IMU5. A priority is set in field 18 to follow up on citizenship documentation in December.

In December, Mrs. Portico is not able to provide the documentation of citizenship, but provides the eligibility specialist proof that she has contacted the county clerk's office in the county where she was married to obtain a copy of her marriage license. The eligibility specialist sets a priority to follow up in March.

FAMIS Cases

When completing the controlled flow for an applicant that meets all eligibility requirements other than documentation of citizenship, take the following actions:

• Enter "PEND" in the Citizen Document field.
• Leave the "Ver" field blank.
• Complete the controlled flow. The TECH result for citizenship shows pending, and there is an outstanding verification for documentation of citizenship.
• Allow the system to create and send an FA325 Request for Information to the participant overnight to request documentation of citizenship.

• Fastpath to the Citizenship Verification (FM8X or CITVERF) screen the next day and enter a "CS" in the "Ver" field.
• Complete an eligibility determination (EDRES). The case passes on citizenship.
• If no other information is needed, authorize the approval of the case.
• Set a reminder for 90 days to follow up on citizenship documentation.

If documentation has not been provided within 90 days, take the following actions:

• Remove the "CS" verification code entered in the "Ver" field on the Citizenship Verification (FM8X) screen.
• Complete an eligibility determination. Citizenship verification now shows pending.
• FAMIS sends the participant an FA-325 Request for Information to provide documentation of citizenship within 10 days.
• If the participant fails to provide documentation within 10 days, the system initiates the adverse action process to discontinue coverage for all active participants for whom citizenship documentation has not been provided.

If the participant is making a good faith effort to provide documentation, take the following actions:

• Add the “CS” verification code again in the “Ver” field on the Citizenship Verification (FM8X) screen.
• Complete an eligibility determination (EDRES). The case passes on citizenship, and
• Set a new reminder to follow up in another 90 days.

System changes to simplify the approval process when documentation of citizenship is pending will be announced in a separate memorandum once implemented in FAMIS.

EXAMPLE: Ms. Terry applied for MO HealthNet for Families (MHF) on 7-20-09. Ms. Terry meets all eligibility requirements for MHF except for documentation of citizenship. The eligibility specialist enters "PEND" in the Citizen Document field and leaves the "Ver" field on the Citizenship Verification (FM8X) screen blank. When the controlled flow is completed, the TECH result for citizenship shows pending, and there is an outstanding verification for documentation of citizenship. Overnight the system sends Ms. Terry an FA325 Request for Information requesting documentation of citizenship. The following day the eligibility specialist fastpaths to the Citizenship Verification (FM8X or CITVERF) screen, enters a "CS" in the "Ver" field, and completes an eligibility determination (EDRES). Ms. Terry passes on citizenship. The eligibility specialist approves Ms. Terry’s MHF application and sets a reminder for 90 days to follow up on citizenship documentation.

Ms. Terry fails to provide documentation of citizenship within 90 days. The eligibility specialist removes the "CS" verification code entered in the "Ver" field on the Citizenship Verification (FM8X or CITVERF) screen in FAMIS and completes an eligibility determination. Citizenship verification is now pending. The eligibility specialist sends Ms. Terry an FA-325 Request for Information to provide documentation of citizenship within 10 days. Ms. Terry fails to provide documentation within 10 days and does not contact the eligibility specialist about making a good faith effort to obtain documentation. The system initiates the process to remove Ms. Terry’s MHF eligibility.

NECESSARY ACTION:

• Review this memorandum with all appropriate staff.
• Effective immediately, begin approving MO HealthNet applicants who meet all eligibility requirements other than citizenship documentation, allowing the participant a reasonable opportunity to provide documentation of citizenship when the applicant declares to be a citizen or national of the United States.

ER