SR 10-31 Dated 12/10

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION

SUMMARY

This SR releases:

·   the implementation of the electronic data crossmatch between New HEIGHTS and the Social Security Administration (SSA), which allows for quicker verification of identity and citizenship for applicants of all categories of financial and medical assistance (see SR 10-11, dated January 2010, for additional information about the SSA Crossmatch). At the time of the release of SR 10-11, funding and resources were not available to develop the SSA Crossmatch. However, over the summer of 2010 both became available and the SSA Crossmatch became operational as of August 27, 2010. The SSA Crossmatch removes the burden on applicants to provide original paper proof of citizenship and identity as a condition of eligibility for financial and medical assistance. A successful match fulfills the citizenship and identity requirements mandated by the Deficit Reduction Act of 2005 (DRA), and no further documentation is needed from the applicant.

The activation of the SSA Crossmatch additionally resulted in the creation of a new New HEIGHTS-generated letter, DX0011, Citizenship Verification Request, and new DFA Form 800CITZ, Citizenship & Identity Acceptable Proofs, which is inserted with the DX0011. The DX0011 is generated when the SSA Crossmatch fails to confirm information provided by individuals applying for financial and medical assistance. It informs the applicant that the crossmatch failed to verify citizenship and identity and that the applicant now has 95 days from the date of the notice to present acceptable documentation. New DFA Form 800CITZ lists the types of acceptable documents the applicant may provide, and is based on the 4-tier chart of acceptable proof of citizenship and identity originally released in SR 08-06, dated July 1, 2006.

·   a revised definition of "reasonable opportunity." New applicants of financial or medical assistance who cannot participate in the SSA Crossmatch will now also have 95 days to provide original paper documentation of citizenship and identity, instead of up to their next redetermination as originally released in SR 10-11. This revision ensures statewide parity in the time periods allowed to provide this proof.

POLICY

SSA Crossmatch

DFA SR 10-11, dated January 2010, released policy on a new option that allowed NH to verify citizenship and identity for applicants of all categories of financial and medical assistance using a crossmatch process with the SSA. This crossmatch was developed during the summer of 2010 and went into production the evening of August 27, 2010. The SSA Crossmatch uses the financial and/or medical assistance applicant’s SSN, name, and date of birth (DOB) to verify citizenship and identity information with SSA records. All applicants of financial and medical assistance who provide us with their SSN, name, and DOB, will be electronically crossmatched against SSA citizenship and identity records. Per SR 10-11, applicants whose information is verified via this SSA Crossmatch have met all citizenship and identity verification requirements for all DFA financial and medical assistance programs and do not have to provide original paper documentation of citizenship and identity.

Applicants whose citizenship fails to be verified by the SSA Crossmatch are sent New HEIGHTS-generated DX0011, Citizenship Verification Request, and DFA Form 800CITZ, Citizenship & Identity Acceptable Proof. New HEIGHTS-generated DX0011 alerts the applicant that the SSA Crossmatch could not verify their citizenship and identity, and informs the applicant that they will now need to provide original paper documentation of citizenship and identity within 95 days from the date of the DX0011. The DX0011 was released under separate cover by New HEIGHTS. DFA Form 800CITZ is mailed along with the DX0011 and lists the tiers of acceptable citizenship and identity documentation as originally released in SR 08-06. A copy of DFA Form 800CITZ and its associated instructions have been attached to this SR.

Reasonable Opportunity Period

The reasonable opportunity period allowed for applicants to provide documentary proof of citizenship and identity has been redefined as 95 days from the date of the notice of decision:

·   For applicants who are able to use the SSA Crossmatch, the notice of decision is the DX0011.

·   For applicants who are not able to use the SSA Crossmatch, the notice of decision is the generic open notice for financial or medical assistance.

If an applicant is otherwise eligible for financial or medical assistance, and the lack of proof of citizenship and/or identity is the only reason that prevents a determination of eligibility, the applicant’s financial and medical assistance cannot be delayed, denied or terminated during the 95-day reasonable opportunity period. If acceptable proof of citizenship and identity is not provided by the end of the 95 days, deny or terminate financial assistance for the entire assistance group and medical assistance for each individual who failed to provide acceptable proof of citizenship and identity.

NEW HEIGHTS AND DISTRICT OFFICE PROCEDURES AND IMPLEMENTATION

On August 27, 2010 New HEIGHTS implemented the SSA Crossmatch as follows: New HEIGHTS transmits the SSN, name, and DOB of each applicant for financial and medical assistance to the SSA where an electronic crossmatch occurs with SSA records to verify the applicant’s citizenship and identity. If the applicant’s SSN, name, and DOB are verified via the SSA Crossmatch, the applicant’s citizenship records will also be crossmatched. If this crossmatch is successful, the individual is considered to have provided acceptable documentation of citizenship and identity. If the applicant’s SSN, name, or DOB cannot be verified via the SSA Crossmatch or the next level of the SSA Crossmatch fails, this information is communicated to New HEIGHTS and the DX0011 is then automatically generated. The DX0011 notifies the applicant that their citizenship and identity could not be verified via a crossmatch with SSA records and that they must provide paper proof of citizenship and identity within 95-days from the date of the DX0011. Form 800CITZ is inserted for mailing with the DX0011 and identifies the types of acceptable original paper documentation of citizenship and identity that can be provided for verification.

Additionally, New HEIGHTS created a new field on the "Additional Demographics" screen in the "Citizenship Information" section called "Medicaid/HKS Verification." When New HEIGHTS receives a positive response from the SSA Crossmatch, where citizenship/identity has been validated, the new "Medicaid/HKS Verification" field on the "Additional Demographics" screen is updated to a value of "SSA Validated." A nightly job is also run to determine the time period that has elapsed since the generation of the DX0011. If the "Medicaid/HKS Verification" field is still marked as "Not Yet Verified" and 95 days have elapsed since the generation of the DX0011, this field will be automatically changed to "Failed/Refused to Verify." NOTE: Because this field is only automated in relation to the generation of the DX0011, and the DX0011 will not be generated to those applicants who are not run through the SSA Crossmatch, Family Services Specialist (FSS) will need to set an expected change for 95 days out from the generic open notice for all applicants who are not run through the SSA Crossmatch. If original paper documentation has not been provided by the 95th day, enter "Failed/Refused to Verify" in the "Medicaid/HKS Verification" field and rerun eligibility.

Special Situations that May Be Encountered During Implementation of this Policy:

·   If an individual contacts the District Office after receiving a DX0011 because the SSA Crossmatch failed to verify the individual’s citizenship and identity, request verification of the applicant’s SSN, DOB, and name to ensure that all information (numbers and spelling) has been entered correctly into New HEIGHTS and any discrepancies have been fixed. If the SSN, name, or DOB have to be corrected, the Family Services Specialist (FSS) must then go to the "DX Manual Request" screen and select the SSA Citizenship Verification button. This will trigger a new SSA Crossmatch for the individual. If the FSS finds no inconsistencies that could have caused an unsuccessful SSA Crossmatch in the original information as provided and verified by the applicant, the applicant must verify citizenship and identity by providing acceptable original paper documentation by the end of the 95-day reasonable opportunity period. Once the paper proof is provided, the FSS must mark the "Medicaid/HKS Verification" field as "Worker Validated."

·   newborns born to mothers who were receiving Medicaid at the time of the baby’s birth, whether or not the newborn will be living with the mother after the newborn’s birth, have automatically met all citizenship and identity verification requirements and are eligible for Medicaid for a full year after the baby’s birth, per SRs 10-11 and 10-28. This means that the Department will consider the newborn to have met all citizenship and identity verification requirements for the period of time that the newborn remains on assistance. This time period will be at least a year, but includes any subsequent periods of eligibility after that initial eligibility year passes, for as long as redeterminations are completed timely. However, SSN program requirements remain unchanged. This means that if the DFA financial or medical assistance program requires an SSN as a condition of eligibility, an SSN must still be provided for the newborn; however, lack of an SSN will not prevent the newborn from being eligible for medical assistance for the first year of mandated medical coverage, as long as the newborn was born to a mother receiving Medicaid at the time of the baby’s birth. If the SSN has not been provided by the newborn’s next redetermination of eligibility, and it is required by the program of assistance for which the newborn’s continued eligibility is being redetermined, the SSN must be supplied as a condition of eligibility for the program of assistance. Even if the newborn’s SSN is still needed at redetermination, this number is only needed to fulfill SSN program requirements, and is still not needed for identity or citizenship policy (and a manually requested crossmatch with SSA is not required), as those specific program verification requirements have been met for as long as the newborn continues to remain eligible for assistance.

·   For all other applicants who are not required to provide an SSN at application or applicants who cannot provide their SSN at application and must therefore verify their application for an SSN (other than newborns born to mother’s receiving Medicaid at the time of the baby’s birth), do the following: If the applicant is otherwise eligible for the program for which they are applying, and lack of proof of citizenship and/or identity is the only reason that prevents a determination of eligibility, the individual must be allowed the 95-day period to provide such proof, per the policy stated above. If at any time during the 95-day period the individual voluntarily supplies verification of their SSN when one is not required, or an applicant who has applied for their SSN later receives and furnishes verification of the new SSN to the Department, the FSS, after reverifying the individual’s name, DOB, and SSN, must manually request a crossmatch with SSA. The SSA Crossmatch will then either verify or fail to verify the individual’s citizenship and identity. If the SSA Crossmatch fails to verify the individual’s citizenship and identity, New HEIGHTS will generate DX0011. The applicant then has 95 days from the date of the DX0011 to provide acceptable documentary proof of citizenship and/or identity. Because the FSS will have verified all needed SSA Crossmatch information prior to manually requesting the SSA Crossmatch for this first time, the individual will need to provide original paper proof of citizenship and identity, per policy, by the end of the 95-day period. No additional SSA Crossmatches need be requested. Once the paper proof is provided, the FSS must mark the "Medicaid/HKS Verification" field as "Worker Validated."

·   While the SSA crossmatch can prove citizenship and identity, it does not prove the age of the child or relationship of the child to a specified relative, both of which are still needed as part of the eligibility determination process for such programs as Financial Assistance to Needy Families (FANF) and NH Child Care Scholarship. The types of acceptable proof that are required to prove both program requirements, which may include a birth certificate, remain unchanged from current policy described in Family Assistance Manual 207.13, Verification.

DESCRIPTION OF REVISIONS MADE TO FORMS

New DFA Form 800CITZ, Citizenship & Identity Acceptable Proof, was created to assist with the SSA Crossmatch process. This one-page double-sided form lists the tiers of acceptable paper citizenship and identity documentation that the applicant must provide, as originally released in SR 08-06, dated July 1, 2006. Although this new form will primarily be used by the mailroom to be inserted with the DX0011 letters that are generated when the SSA Crossmatch fails to confirm the financial or medical assistance applicant’s citizenship and identity, the paper form is also available from the DHHS warehouse, and electronically for Department staff on the Lotus Notes Family Services Database. The form can be ordered through the regular forms ordering process when the office needs a supply. Instructions for this form were created accordingly, and both documents have been attached to this SR.

POLICY MANUAL REVISIONS

Revised Family Assistance Manual Topics

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

New HEIGHTS began implementation of the SSA Crossmatch on August 27, 2010. On September 1, 2010, the first DX0011 letters were generated out of New HEIGHTS and mailed with DFA Form 800CITZ to applicants whose citizenship or identity information could not be confirmed through the electronic data crossmatch with the SSA. The change in the reasonable opportunity period from the next redetermination period to 95-days is effective December 17, 2010.

CLIENT NOTIFICATION

Notification of the changes in the citizenship and identity verification and reasonable opportunity policy was published in the NH Rulemaking Register, Office of Legislative Services, on October 8, 2010. A public hearing on the amended Administrative Rules was held on October 29, 2010. No other client notification is planned.

TRAINING

No training is planned or needed.

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 www.dhhs.nh.gov/DFA/publications.htm, effective January 31, 2011. 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