MASSHEALTH CITIZENSHIP VERIFICATION

Although the federal proof of citizenship requirements go into effect on July 1, 2006, MassHealth will not be enforcing the requirements until July 17, 2006. By the end of this week (probably late Friday afternoon), MassHealth will be issuing the state specific guidelines and will allow providers two weeks to change current operations to come into compliance with the guidelines. A few additional issues to note:

The states are still awaiting clarification from the federal government on some provisions outlined in the federal guidance to state Medicaid directors that was released on June 9th. MassHealth believes that this will only apply to half of their members, since they plan to match citizenship information electronically for anyone also receiving SSI, TANF, Food Stamps, or Medicare. That leaves approximately 500,000 members for whom this will be a requirement.

Undocumented non-citizens will not be affected by this new requirement. They will complete a Virtual Gateway application, checking off that they are not a citizen. The state will then review them only for Free Care, MassHealth Limited, Healthy Start, or CMSP (the programs for which citizenship is not a requirement) and will determine their eligibility.

The June 9th letter outlines a "hierarchy" of acceptable documentation, with a U.S. Passport, Certificate of Naturalization, or Certificate of Citizenship being the preferred types of documentation. If those documents are not available, a range of other items (such as birth certificates) is acceptable; however, other documentation must be accompanied by proof of identity such as a driver’s license with a photo or written identifying information (such as age, gender, eye color, etc). There had been some rumors that written affidavits might be acceptable; however, this guidance really restricts the use of affidavits to rare circumstances.

Other issues addressed in the letter include a provision that special assistance be provided to homeless individuals and other special populations such as those who are mentally impaired or physically incapacitated and have no one to act on their behalf. See the letter at: www.cms.hhs.gov/MedicaidEligibility/Downloads/SMD Letter Improved Documentation of Citizenship.pdf

06/06