2010 Kicks Off with Better, More Efficient Way to Document Citizenship – Say Ahhh! A Children’s Health Policy Blog

Each celebration of a new year
brings a renewed sense of optimism and 2010 offers tremendous promise in mitigating
the chilling impact of the citizenship documentation requirement imposed by the
2005 Deficit Reduction Act (DRA) on Medicaid. The citizenship documentation
requirement not only made it more difficult for eligible citizens to enroll in
Medicaid but states have also spent millions of dollars in administrative costs
to comply with the regulation. The title of a study by the Government
Accountability Office
it well: “States
Reported that Citizenship Documentation Requirement Resulted in Enrollment
Declines for Eligible Citizens and Posed Administrative Burdens.” 

But hope is on the horizon. Beginning on day one of this new
decade, State Medicaid agencies can use an electronic data exchange with the
Social Security Administration (SSA) to verify citizenship in lieu of the
cumbersome and complex regulations that many believe went beyond the letter of
the law to implement the DRA requirement. According to friends at CMS, every
state has entered into new contracts with SSA enabling them to move forward
with the electronic data exchange. Early reports indicate that ten states
already have enhanced their systems and submitted transactions to SSA for
citizenship verification. This is indeed worth a round of fireworks or a toast
of the bubbly! 
So the uptake is that it is no longer necessary for states
to require applicants to provide paperwork proving citizenship or nationality.
While we may need to be patient for states to implement the system changes
necessary to accommodate the new SSA data exchange, cost should not be a
barrier. The federal government is picking up 90% of the development and
implementation costs. A state’s 10% share should quickly be offset in administrative
cost reductions, particularly considering that the data exchange builds upon an
existing system infrastructure under the State Verification and Exchange System
Coinciding with the launch of the SSA data exchange is the
release of the eleventh CHIPRA Letter to State Officials (SHO) from
the Center for Medicaid and State Operations (CMSO) providing guidance to
states in implementing the citizenship documentation provisions of the
Children’s Health Insurance Program Reauthorization Act (CHIPRA): 
  • States must provide applicants with at least the
    same reasonable opportunity to submit satisfactory evidence of citizenship that
    immigrants are given to provide satisfactory immigration status.
  • If applicants for Medicaid or CHIP have declared
    citizenship and have met all eligibility and verification requirements except
    citizenship documentation, states cannot delay, deny, reduce or terminate
    Medicaid or CHIP eligibility. 
  • Babies who are initially eligible for Medicaid
    or CHIP as “deemed newborns” are not required to submit documentation at
  • Tribal enrollment or membership documents issued
    by a federally recognized Tribe must be accepted as verification of
  • Citizenship documentation requirements now apply
    to CHIP programs aligning requirements with both Medicaid and CHIP-funded
    Medicaid expansion programs. 

We tip our glasses to CMSO
and SSA for meeting the January 1, 2010 implementation date for the new
citizenship documentation data exchange and to the ten states that are early
participants. Here’s hoping that soon we can report that all states are using
the latest technology to streamline eligibility and enrollment in Medicaid and

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