Adult Medicaid Admin. Letters

DMA ADMINISTRATIVE LETTER NO. 08-09 CITIZENSHIP DOCUMENTATION

DAAS ADMINISTRATIVE LETTER NO. 09-24

ECONOMIC AND FAMILY SERVICES EFS_WF_AL-11-2009

DATE: DECEMBER 21, 2009

SUBJECT: CITIZENSHIP DOCUMENTATION

DISTRIBUTION: COUNTY DIRECTORS OF SOCIAL SERVICES

INCOME MAINTENANCE DIRECTORS

MEDICAID CASEWORKERS AND SUPERVISORS

NCHC CASEWORKERS AND SUPERVISORS

WORK FIRST CASEWORKERS AND SUPERVISORS

SPECIAL ASSISTANCE CASEWORKERS AND SUPERVISORS

I. BACKGROUND

The Deficit Reduction Act of 2005 (P.L. 109-171) mandated that all Medicaid applicants and recipients claiming to be citizens of the United States must provide documentation of citizenship. The Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA or Public Law 111-3) modifies the Deficit Reduction Act of 2005 to extend those requirements to North Carolina Health Choice applicants and recipients. Effective January 1, 2010, the requirement to provide documentation of US citizenship applies to applicants and recipients of North Carolina Health Choice (NCHC).

Effective January 11, 2010, a Social Security Administration (SSA) Citizenship match is available through EIS. A returned accurate match may be used for verification of both citizenship and identity for any NCHC or Medicaid applicant, including Special Assistance and Work First. CMS and SSA are not allowing states to send matches for any existing recipients; only applicants. When existing recipients who have not been documented come up for review, the documentation must be obtained using policy guidelines that were in place prior to January 1, 2010. The SSA data match is completed only for applicants who state they are U.S. citizens.

Refer to Adult Medicaid 2505, Family and Children’s Medicaid 3331 (Citizenship/Identity SSA Data Match), Special Assistance 3245 and Work First Manual Sections 111 and 130 for additional policy information.

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Please Note: Special Assistance manual section 3245 is unavailable at this time. A terminal message and listserve message will be sent to the counties to inform them when it becomes available.

II. RESPONSIBILITIES OF THE INCOME MAINTENANCE CASEWORKER

A. At Application (New Applicant)

1. A new citizenship indicator (CTZ field) on the DSS-8124 application is available effective January 11, 2010. This indicator allows a caseworker to enter a response when an application is taken. The indicator represents whether the applicant has stated he is a U.S. Citizen. The field is required for all aid programs except SCD, MRF and RRF.

2. Beginning January 11, 2010, for all applications keyed January 4, 2010 through January 8, 2010, the caseworker must redisplay the DSS-8124 and enter the appropriate response. It is not required but you may also choose to redisplay applications taken prior to January 1, 2010, and enter the citizenship response so that a citizenship match will be completed.

3. The responses that should be entered on the DSS-8124 are as follows:

a. “Y” Individual is applying for assistance and states he is a U.S. Citizen.

b. “N” Individual is applying for assistance and states he is not a U.S. Citizen. For SCD, MRF and RRF, EIS automatically enters an “N” in the field.

c. “X” Casehead not applying for benefits or individual who states he is a U.S. Citizen and does not have a social security number.

4. For all applicants with a “Y” in the CTZ field on the DSS-8124, EIS changes the indicator on the DSS-8124 from “Y” to “S” (Sent) when the information is sent to SSA for verification of citizenship and identity.

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5. A daily file is sent to SSA to verify citizenship and identity for all applicants for whom the caseworker entered a “Y” indicator for citizenship. These files are sent Monday through Friday at approximately 5:30 P.M. The caseworker should expect an SSA response returned within 24 to 48 hours. Anything keyed after 5:30 P.M. will not be sent until the following workday.

6. Some queries may be returned due to exceptions in the data such as Name, Date of Birth or SSN not matching the SSA data. If SSA finds an exception, EIS changes the indicator from “S” (Sent) to “E” (Exception). Follow-up is required by the caseworker. The citizenship match data is not returned until the exception is resolved. Refer to #9 below.

7. Once all exceptions are resolved, there are 4 possible SSA responses for citizenship.

SSA Response Code	Code Description
A	SSN is verified, there is no indication of death, and the allegation of citizenship is consistent with SSA data.
B	SSN is verified, there is no indication of death, and the allegation of citizenship is NOT consistent with SSA data.
C	SSN is verified, there is indication of death, and the allegation of citizenship is consistent with SSA data.
D	SSN is verified, there is indication of death, and the allegation of citizenship is NOT consistent with SSA data.

8. Responses from SSA and exceptions are placed on a report in NCXPTR for the caseworker to review. This report is updated daily. The report is titled DHRWDB CITIZENSHIP APP RESPONSE.

9. DHRWDB CITIZENSHIP APP RESPONSE Report

a. The report is sorted by County Name and Number, District Number, Application Number and Post Date. The report displays the newest (based on post date) application first.

b. There is a page break for each County and District Number.

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c. Included on the report is the following information:

1) County Name and Number

2) District Number

3) Casehead Payee Name

4) Application Number

5) Individual Line Number of each applicant on the application.

6) Responses are V (Verified), E (Exception) or SSA response (A,B,C,D).

For individuals without a SSN and caseheads who are not applicants, the line number has a space as the response. These individuals are not sent to SSA.

d. The report is retained for 1098 days.

e. The report is cumulative and displays all applications until they are dispositioned.

Note: If the application is dispositioned before the response is returned, the application is not displayed on the report.

10. The caseworker must review the DHRWDB CITIZENSHIP APP RESPONSE Report daily.

a. If response code “A” is returned, no action is required by the caseworker. EIS automatically places citizenship code “11” and the date on the DSS-8125 when the caseworker dispositions the application.

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b. If response code “B” is returned, the caseworker must resolve citizenship and identity by following the instructions in MA-2505/3331, SA-3245 or WF-111. If there is no resolution and all other eligibility factors are met, approve the application and authorize with the correct certification period. The caseworker approves using a citizenship code “97” for all applicants with no resolution. The date entered is the date the first request for information (DMA-5097 or DSS-8146A) is sent to the applicant requesting documentation of citizenship and identity. The case is placed on the Case Management Report listing the 90th day from the date the DMA-5097/DSS-8146A was issued. If citizenship and identity are not resolved by the 90th day, send a timely notice to terminate the case or individual with the appropriate termination reason. See III below.

c. If response code “C” is returned, the caseworker needs to resolve the indication of death. When resolved, the caseworker enters a citizenship code “12” for the applicant on the DSS-8125. The date entered is the date the caseworker resolved the death issue. See MA-2505/3331, SA-3245 or WF-111.

d. If response code “D” is returned, the caseworker must resolve citizenship and identity by following the instructions in MA-2505/3331, SA-3245 or WF-111. When resolved, the caseworker enters the correct citizenship code at approval. If no resolution and the individual is not deceased, the caseworker approves the application using a citizenship code “97”. The date entered is the date the first request for information (DMA-5097/DSS-8146A) is sent to the recipient to request documentation of citizenship and identity. The case is placed on the Case Management Report listing the 90th day from the date the DMA-5097/DSS-8146A was issued.

e. If response code “E” is returned, the caseworker must resolve the exception. When resolved, the caseworker updates the individual with the correct information by using the Name Change function. The caseworker also changes the indicator from “E” to “Y” on the DSS-8124, EIS resends to SSA for citizenship and identity documentation.

Note: Citizenship and Identity can not be documented until exceptions are resolved.

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11. There are some instances in which SSA cannot document citizenship and identity due to spelling of the names. For example, if SSA has the applicant’s name listed with a hyphen, EIS does not allow names to be keyed using hyphens or embedded spaces, therefore the discrepancy cannot be resolved. The caseworker must document citizenship and identity by requesting documentation from the applicant. See MA-2504/3330, SA-3245 or WF-111.

B. Reapplication

1. Key the DSS-8124 completing the U.S. Citizenship Field (CTZ) for each applicant using one of the following responses.

a. “Y” Individual is applying for assistance and states he is a U.S. Citizen.

b. “N” Individual is applying for assistance and states he is not a U.S. Citizen. For SCD, MRF and RRF, EIS automatically enters an “N” in the field.

c. “X” Casehead not applying for benefits or individual states he is a U.S. Citizen and does not have a social security number.

2. For all applicants with a “Y” in the CTZ field on the 8124, EIS checks the Individual Database to verify if there was a previous valid citizenship code.

a. If EIS finds Citizenship Code “10” or “25”, EIS automatically changes the indicator from “Y” to “V” (Verified) on the DSS-8124. No other action is needed to document citizenship.

b. If EIS finds citizenship code “11” or “12”, EIS automatically changes the indicator from “Y” to “A” or “C” (the response returned from SSA).

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c. If EIS finds citizenship code “97” was previously in the citizenship field, “Y” is replaced with the latest SSA response code (See II.A.7 above for SSA response codes). For response code of “B” or “D”, citizenship and identity, the caseworker must resolve before the case can be approved. EIS does not allow citizenship code "97” to be reentered on the DSS-8125. The caseworker must enter a valid citizenship code at approval or pend the application for 6 months. If citizenship and identity are not resolved at the end of the 6th month, deny the application with the appropriate denial reason. Refer to III below.

d. For all other codes with “Y” indicator on 8124, EIS sends a request to SSA to document citizenship and identity. The indicator is changed from “Y” to “S” (Sent) on the DSS-8124 when the information is sent to SSA. No action is needed by the caseworker at this time.

3. Refer Back to II. A.4-A.10 (At Application).

C. Redetermination/Review

For all recipients who state they are a U.S. citizen and citizenship has not been documented, the caseworker must review the case record and other agency records for documentation.

If documentation is available, the caseworker enters the correct citizenship code when the redetermination is keyed.

If documentation is unavailable, the caseworker must request documentation of citizenship by following the procedures listed in MA-2504/3330, SA-3245 or WF-111.

If all other documentation is received except citizenship and identity, the caseworker keys the redetermination using citizenship code “97”. The date entered is the date the first request for documentation (DMA-5097/DSS-8146A) is sent. The case is placed on the Case Management Report with the 90^th day. If citizenship and identity are not resolved by the 90^th day, send a timely notice to terminate the case or individual using the appropriate termination reason. See III below.

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III. AUTOMATIC NOTICE CODES

A. NC Health Choice

NOTICE TYPE	NOTICE CODE	NOTICE TEXT
Approval	B8	The following individual(s) is approved for NCHC for the months of _____ thru ______. You must provide verification of citizenship and/or identity to continue to receive NCHC. If documentation is not received, your NCHC will be terminated. Section MA-3331.
Denial	N1	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-3331.
Termination (Timely)	2R	You have failed to provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-3331.
Termination (Adequate)	6R	You have failed to provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-3331.
Individual Deletion (Timely)	4W	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-3331.
Individual Deletion (Adequate)	9W	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-3331.

B. Medicaid

NOTICE TYPE	NOTICE CODE	NOTICE TEXT
Approval	B8	The following individual(s) is approved for Medicaid for the months of _____ thru ______. You must provide verification of citizenship and/or identity to continue to receive Medicaid. If documentation is not received, your Medicaid will be terminated. Section MA-2505/3331.
Denial	N1	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-2505/3331.
Termination (Timely)	2R	You have failed to provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-2505/3331.
Termination (Adequate)	6R	You have failed to provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-2505/3331.
Individual Deletion (Timely)	4W	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-2505/3331.
Individual Deletion (Adequate)	9W	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section MA-2505/3331.

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C. Work First Family Assistance

NOTICE TYPE	NOTICE CODE	NOTICE TEXT
Approval	B8	The following individual(s) is approved for Medicaid for the months of _____ thru ______. You must provide verification of citizenship and/or identity to continue to receive Medicaid. If documentation is not received, your Medicaid will be terminated. Section WF-111.
Denial	N1	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section WF-111.
Termination (Timely)	2R	You have failed to provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section WF-111.
Termination (Adequate)	6R	You have failed to provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section WF-111.
Individual Deletion (Timely)	4W	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section WF-111.
Individual Deletion (Adequate)	9W	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section WF-111.

D. Special Assistance

NOTICE TYPE	NOTICE CODE	NOTICE TEXT
Approval	B8	The following individual(s) is approved for Medicaid for the months of _____ thru ______. You must provide verification of citizenship and/or identity to continue to receive Medicaid. If documentation is not received, your Medicaid will be terminated. Section SA-3245.
Denial	N1	You did not provide documentation of citizenship and/or identity (Individual(s) previously received benefits while trying to resolve citizenship code “97”). Section SA-3245.
Termination (Timely)	2R	You have failed to provide documentation of citizenship and/or identity (Individuals previously received benefits while trying to resolve citizenship code “97”). Section SA-3245.
Termination (Adequate)	6R	You have failed to provide documentation of citizenship and/or identity (Individuals previously received benefits while trying to resolve citizenship code “97”). Section SA-3245.

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IV. CITIZENSHIP INDIVIDUAL OVERLAY RULES

10 overlays 25, 35, 45, 50, or 99

11 overlays anything except 10 or 25

12 overlays anything except 10, 11 or 25

25 overlays 35, 45, or 99

35 overlays 45 or 99

45 overlays 99

50 overlays 35, 45, or 99

97 can be overlaid by anything except 98 and 99

98 can be overlaid by anything except 99

99 can be overlaid by anything

51 and 60-66 can be overlaid by any code

50 can be overlaid by 51 and 60-66

Note: 10,11,12,25 can not be overlaid by any code.

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If you have any questions regarding this information, please contact your Program Representative.

Sincerely,

Craigan L. Gray, MD, MBA, JD

Director

Sherry S. Bradsher, Director

Division of Social Services

Dennis W. Streets, Director

Division of Aging and Adult Services

(This material was researched and prepared by Brenda Gooch, EIS Program Consultant, DMA/EIS Unit.)