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6 the application. When an application interview is required (refer to IHCPPM 2005.00.00), the form should be sent on the date of intake. The names of all persons for whom documentation is required should be listed. Each applicant whose name is on the form will have 95 days to provide proof of citizenship beginning the date after the form is sent. Please note, the “Pending Verifications for Applicants/Recipients” (FI 2032) is not to be used in lieu of this form. Giving the applicant a 95-day deadline (on the FI 2326) to provide the documents. • Assisting the family in locating verification sources when necessary. This would include such things as helping to find websites, telephone numbers or mailing addresses so that out-of-state birth certificates can be ordered. • Entering a detailed case note comment for each contact made with the client regarding citizenship verification.

If an applicant has provided all required criteria to allow for an eligibility determination, except for fulfilling his citizenship verification requirement, the applicant should be determined eligible without undue delay. If documentation of citizenship was not provided to the DFR by the applicant and electronic verification of citizenship through VLP is not received after 95 days after the applicant received “Notification of Requirement to Provide Documentation of Citizenship”, eligibility is to be discontinued. If the person reapplies at least 95 days after being denied for not verifying citizenship, they are eligible for a new ROP. During each succeeding ROP, Medicaid must be authorized if all other eligibility requirements are met (Refer to 2035.40.05). Note: Effective 6/1/24, per CMS guidance, the number of Reasonable Opportunity Period is unrestricted. Members who reapply for Medicaid at least 95 days from initial denial for not verifying satisfactory immigration status or citizenship during their Reasonable Opportunity Period, will acquire a new ROP and if all other requirements are met, Medicaid benefits must be authorized.6

Referring the case to the supervisor so that an inquiry can be sent to the Policy Answer Line (PAL) if there is uncertainty as to whether benefits should be denied or discontinued for failing to meet the citizenship requirement. The applicant may request a birth certificate by telephone, mail, or online at https://www.vitalchek.com/birth-certificates.

There are two general sources of citizenship documentation: primary, for which one source document is acceptable and secondary, which requires a source document for citizenship and proof of identity.

Primary sources of citizenship documentation are: