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2402.20.40 CUBAN AND HAITIAN ENTRANTS Cuban and Haitian Entrants (CHEs), as defined in Section 501(e) of the Refugee Education Assistance Act of 1980, can be eligible for full coverage Medicaid.16 CHE is not a derivative status therefore family members do not automatically acquire CHE eligibility and may be subject to 5- year bar. CHEs can have a wide variety of immigration documentation, that do not categorially establish whether individuals are CHE, therefore SAVE verification is always required.17 Citizenship and immigration status must be verified for all members attesting to CHE eligibility. Note: Children born abroad to Cuban/Haitian Entrants are not considered CHE unless eligibility and immigration status is verified with approved U.S. Immigration documentation that provides evidence of citizenship or nationality and confirmed through SAVE (Refer to 2402.10.15).

Please submit a PAL for questionable CHE eligibility or immigration status.

2402.20.41 COMPACT OF FREE ASSOCIATION (COFA) ENTRANTS Effective December 27, 2020, Compact of Free Association (COFA) Entrants as defined in the 1996 Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), and amended by the Consolidated Appropriations Act, 2021 can now be eligible for full coverage Medicaid if they otherwise qualify. This includes individuals that are citizens of Federated States of Micronesia (FSM), the Republic of the Marshall Islands (RMI), and the Republic of Palau (PAL). COFA citizens are not citizens or nationals of the United States; however, if they live in the 50 U.S. states and District of Columbia and meet all other Medicaid eligibility rules, they may now be considered for full-coverage Medicaid. COFA citizens who meet financial eligibility criteria based on their income and other non- financial eligibility criteria are exempt from the 5-year bar. Medicaid may provide retroactive coverage for up to three months prior to the month of application, if the individual would have been eligible for a category of assistance which includes retroactive coverage during that period had they applied.

NOTE: The only exceptions are: • For children who only qualify for the separate CHIP program (in Indiana, this is aid category MA10), children who are COFA citizens and being determined in MA10 should be processed according to their immigration status without regard to COFA citizenship.