Citzenship Documentation

On July 1, 2006, new citizenship documentation requirements resulting from an amendment to the federal Medicaid statute (title XIX) passed as part of the Deficit Reduction Act of 2005 (DRA) became effective.  The new documentation provision requires all citizens applying for or receiving Medicaid benefits to provide “satisfactory documentary evidence” of their U.S. citizenship and identity. All U.S. citizens who apply for Medicaid or renew their eligibility must prove their citizenship by presenting acceptable documents such as a passport or birth certificate outlined by the law.  The requirement may impact 50 million citizens (both immigrants and non-immigrants) receiving Medicaid, as well as many more seeking to apply.

July 2, 2007 CMS published a final regulation implementing the Medicaid Citizenship Documentation requirement. The final regulation makes some improvements to requirements, most importantly allowing the use of some additional documents to prove citizenship and identity.  In addition, the regulation clarifies existing CMS policy in several areas that may help states understand how to minimize the burden imposed by the requirement on applicants, beneficiaries and states.  However, the final regulation makes it only slightly easier for individuals to meet the documentation requirements in order to qualify and to receive Medicaid benefits.  Eligible U.S. citizens still are at risk of having their Medicaid coverage delayed, denied or terminated because of the strict requirements. 

Senate legislation to reauthorize the State Children’s Health Insurance Program (SCHIP) introduced in July 2007 includes a provision to moderate this requirement in Medicaid by allowing states greater flexibility to accept social security numbers as proof of citizenship and identity.  However, the provision also applies citizenship documentation standards to SCHIP, potentially expanding the impact of the rule.

Citzenship Documentation

On July 1, 2006, new citizenship documentation requirements resulting from an amendment to the federal Medicaid statute (title XIX) passed as part of the Deficit Reduction Act of 2005 (DRA) became effective.  The new documentation provision requires all citizens applying for or receiving Medicaid benefits to provide “satisfactory documentary evidence” of their U.S. citizenship and identity. All U.S. citizens who apply for Medicaid or renew their eligibility must prove their citizenship by presenting acceptable documents such as a passport or birth certificate outlined by the law.  The requirement may impact 50 million citizens (both immigrants and non-immigrants) receiving Medicaid, as well as many more seeking to apply.

July 2, 2007 CMS published a final regulation implementing the Medicaid Citizenship Documentation requirement. The final regulation makes some improvements to requirements, most importantly allowing the use of some additional documents to prove citizenship and identity.  In addition, the regulation clarifies existing CMS policy in several areas that may help states understand how to minimize the burden imposed by the requirement on applicants, beneficiaries and states.  However, the final regulation makes it only slightly easier for individuals to meet the documentation requirements in order to qualify and to receive Medicaid benefits.  Eligible U.S. citizens still are at risk of having their Medicaid coverage delayed, denied or terminated because of the strict requirements. 

Senate legislation to reauthorize the State Children’s Health Insurance Program (SCHIP) introduced in July 2007 includes a provision to moderate this requirement in Medicaid by allowing states greater flexibility to accept social security numbers as proof of citizenship and identity.  However, the provision also applies citizenship documentation standards to SCHIP, potentially expanding the impact of the rule.