MEMORANDUM

DISCUSSION:

Memorandum IM-#54, July 21, 2009 identified 90 days from the date of approval as a reasonable amount of time allowed for a participant to verify citizenship for MO HealthNet programs.  This memorandum provides guidance and further clarification of the procedure when allowing an applicant a reasonable opportunity to present documentary evidence of citizenship and when an individual reapplies after his/her benefits have been discontinued for failure to provide verification of citizenship.

If an applicant does not have verification of citizenship when making an original application for MO HealthNet, he/she is allowed a reasonable amount of time to provide verification of citizenship.  The State of Missouri defines a "reasonable amount of time" as 90 days.  If an applicant meets all other eligibility criteria except citizenship verification, the application for MO HealthNet (MHN) is approved.  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 FA 325 Request for Information to the participant overnight to request documentation of citizenship.  This is an overnight process.
• Fastpath to the Citizenship Verification (FM8X or CITVERF) screen the next day and enter "CS" in the "VER" field.
• Complete an eligibility determination (EDRES).  The case passes on citizenship.
• 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 or CITVERF) screen.
• Complete an eligibility determination.  Citizenship now shows pending.
• FAMIS sends the participant a 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.

NOTE: FAMIS system changes are being made to automate this process.  A follow up memorandum will be issued when the changes are completed.

An individual can reapply for a MO HealthNet program when coverage has been discontinued due to failure to provide citizenship documentation.  However, the application cannot be approved unless verification of citizenship is provided.  If verification of citizenship was not provided during the 90 day timeframe, the case was closed.  When the individual reapplies for MO HealthNet benefits, take the following action when completing the CONFLOWS for the new application if citizenship verification is not provided during the interview:

• 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 FA 325 Request for Information to the participant to request documentation of citizenship.  This is an overnight process.

If verification is not provided, the application is rejected at the end of the application period.  The individual is not allowed an additional 90 day approval while pending for citizenship verification.

Example: On 07/23/2010, Ms. Smith applies for MO HealthNet for Families (MHF) for herself and her three children.  Ms. Smith does not have citizenship documentation for herself or her three children.  Ms. Smith is given a Request for Information (FA-325) notice requesting citizenship documentation, the case is approved, and a reminder is set to follow up 90 days from the date of approval.  Ms. Smith fails to provide documentation within 90 days.  The eligibility specialist removes the "CS" verification code in the "VER" field on the Citizenship Verification (FM8X or CITVERF) screen in FAMIS and a FA-325 Request for Information is sent to Ms. Smith requesting verification of citizenship.  Ms. Smith fails to provide the requested information and does not contact the eligibility specialist (ES) claiming a good faith effort in obtaining the citizenship verification.  FAMIS sends an Adverse Action Notice (FA 410).  When the Adverse Action Notice (FA 410) expires, the MO HealthNet for Families (MHF) case closes.  An Action Notice (FA 450) is sent to Ms. Smith.  On 12-23-10, Ms. Smith reapplies for herself and her three children.  Ms. Smith does not provide verification of citizenship for herself or her three children.  The eligibility specialist (ES) enters "PEND" in the Citizen Document field and leaves the verification field blank on the Citizenship Verification (FM8X or CITVERF) screen in FAMIS.  Ms. Smith’s application will pend (case is not approved) 30 days allowing her an additional 30 days to provide citizenship verification.  Ms. Smith fails to provide verification of citizenship and therefore, her application rejects.

If an applicant who declares they are not a citizen later reapplies for MO HealthNet benefits and claims to be a citizen, or anytime an applicant applies for benefits and their statement of citizenship is questionable, request verification of citizenship prior to approving the application.  Enter "PEND" in the Citizen Document field and leave the verification field blank on the Citizenship Verification (FM8X or CITVERF) screen in FAMIS.  If citizenship documentation is not provided by the end of the application period the system automatically rejects the application for failure to provide documentation of citizenship.

Record comment(s) in Eligibility Unit Member Role (FM3Z or EUMEMROL) and/or Citizenship Verification (FM8X or CITVERF) screens.

NECESSARY ACTION:

• Review this memorandum with all appropriate staff.

HA