SR 10-11 Dated 01/10

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION

SUMMARY

This SR:

·   releases updates on citizenship and identity verification requirements for all applicants of financial and/or medical assistance, based upon mandates and state options released in The Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA), and promulgation of administrative rules; and

·   incorporates the notification of these changes that was sent in a Director’s Memo dated 2/24/10, subject line, The Children’s Health Insurance Program Reauthorization Act of 2009 – Citizenship Documentation Requirements for Medicaid and Healthy Kids-Silver.

SR 08-06, dated July 1, 2006, released stricter citizenship and identity verification requirements for most applicants of all categories of financial and/or medical assistance based on the Deficit Reduction Act of 2005 (DRA). CHIPRA does not make any changes to the DRA citizenship and identity verification requirements, but instead revises some of the groups the stricter DRA verification requirements apply to and offers greater latitude to states in implementing those stricter requirements. The new policies are as follows:

·   Healthy Kids Silver (HKS) applicants are no longer exempt from meeting the stricter citizenship and identity verification requirements released in SR 08-06;

·   if new applicants for financial and/or medical assistance are unable to meet the citizenship and identity verification requirements released in SR 08-06, and the inability to provide this documentation is the only reason which prevents a determination of eligibility for the applicant household, then the household will no longer be automatically denied assistance. Instead, the household will have until their next redetermination to provide the required documentation. If citizenship and identity verification is not provided at the next scheduled redetermination, terminate financial assistance for the entire assistance group and medical assistance for the household members who have failed to provide the documentation;

·   newborns born to a mother who is currently receiving Medicaid, HK, or Medical Coverage for Pregnant Women (MCPW), are considered to have met citizenship and identity verification requirements; and

·   once a crossmatch between New HEIGHTS and the Social Security Administration (SSA) becomes available, this crossmatch will be able to be used in lieu of paper proof of citizenship and identity for most financial and/or medical assistance applicants. It is anticipated that this crossmatch will increase the ease and speed in which applicant eligibility can be determined.

Form 800, Application for Assistance, was revised to add information about the crossmatch with SSA.

POLICY

Policy released in this SR does not change any of the citizenship and identity documentation requirements previously released in SR 08-06. However, this SR modifies some of the groups that the requirements apply to and provides more leniency in the application of those documentation requirements, as follows:

·   although previously excluded from the stricter citizenship and identity verification requirements described in SR 08-06, HKS applicants are now required to provide this documentation;

·   if applicants for financial and/or medical assistance meet all other program eligibility requirements but are unable to provide the citizenship and identity documentation as released in SR 08-06, and the inability to provide this documentation is the only reason which prevents a determination of eligibility for the applicant household, then the household will no longer be automatically denied assistance. Instead the household will have until the next scheduled redetermination to provide the required documentation. If the required documentation is not provided at the next redetermination, terminate financial assistance for the entire assistance group and medical assistance for the individuals who have failed to provide documentation;

·   any newborn born to a mother who is currently receiving Medicaid, HK, or MCPW is considered to have met citizenship and identity verification requirements. No further citizenship or identity documentation for the newborn is required at subsequent redeterminations; and

·   once a crossmatch between New HEIGHTS and the SSA becomes available, this crossmatch will be able to be used in lieu of paper proof of citizenship and identity for most financial and/or medical assistance applicants. To utilize this crossmatch, clients will have to provide the Department with their SSN. Most programs of assistance require an SSN as a condition of eligibility so the SSN will already have been collected. However, the HKS program does not require an SSN as a condition of eligibility. This policy remains unchanged; HKS applicants do not need to provide an SSN as a condition of eligibility. However, if the HKS applicant voluntarily provides their SSN, this crossmatch will be able to be used for HKS applicants as well.

NEW HEIGHTS SYSTEMS PROCEDURES AND IMPLEMENTATION

New HEIGHTS has incorporated the changes released in this SR.

Automation of the 4-tiered acceptable proofs of citizenship and identity verification released by SR 08-06 is still in development. New HEIGHTS will release information on the automation under separate cover at a later date, once it is available.

DESCRIPTION OF REVISIONS MADE TO FORMS

Text in DFA Form 800, Application for Assistance, was revised to indicate that HKS applicants, although not required to do so, may choose to provide SSNs that can be used in a data crossmatch with SSA to shorten their eligibility verification process.

Since the usage of Form 800 is not changing, no updates were made to the instructions, Form 800(i).

The current version of Form 800 and all previous versions remain valid and should be used until the current supply has been depleted, at which time the new version will be printed.

POLICY MANUAL REVISIONS

Revised Family Assistance Manual Topics

Section 215.05  Who Is Not a Member

Section 220.03  Healthy Kids Silver (HKS) Eligibility Requirements

Section 220.13  Healthy Kids Silver (HKS) Verification Requirements

Section 301.07  Verification of Identity

Section 305.05  Verification of Citizenship

Revised Adult Assistance Manual Topics

Section 305.05  Verification of Citizenship and Identity

IMPLEMENTATION

All policy released in this SR is retroactively effective to January 1, 2010. However, no District Office action is needed to implement retroactively because the policy was implemented via the Director’s Memo dated 2/28/10, subject line, The Children’s Health Insurance Program Reauthorization Act of 2009 – Citizenship Documentation Requirements for Medicaid and Healthy Kids-Silver.

The revised Form 800, Application for Assistance, will be printed once the current supply is exhausted. Continue using the current version of Form 800, as well as all previous versions, until the current supply has been depleted.

CLIENT NOTIFICATION

Notification of the following changes requiring administrative rule amendments is anticipated to be published in the NH Rulemaking Register, Office of Legislative Services, in May 2010:

·   allowing until the next redetermination to provide citizenship and identity documentation;

·   utilizing a crossmatch with SSA in lieu of paper citizenship and identity documentation; and

·   ensuring the policy related to newborn citizenship and identity verification criteria aligns with the CHIPRA changes.

A public hearing on the amended Administrative Rules is planned for June 2010. No other client notification is planned.

TRAINING

A Director’s Memo was issued on 2/24/10 detailing the new CHIPRA mandates. No further training is planned.

FORMS MANUAL POSTING INSTRUCTIONS

DISPOSITION

This SR may be destroyed or deleted after its contents have been noted and the revised manual topics released by this SR have been posted to the On-line manuals.

DISTRIBUTION

This SR will be distributed according to the electronic distribution list for Division of Family Assistance policy releases. This SR, and revised On-Line Manuals, will be available for agency staff in the On-Line Manual Library, and for public access on the Internet at http://www.dhhs.nh.gov/DHHS/DFA/LIBRARY, effective May 3, 2010. Additionally, this SR, and printed pages with posting instructions, will be distributed under separate cover to all internal hard copy holders of the Family Assistance, Adult Assistance and Forms Manuals.

DFA/KD:s