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Immigration status must be verified through electronic data sources. When an electronic data source cannot validate immigration status or if it differs from the documentation provided to the OPA, additional verification is required. Acceptable verifications include current unexpired documents that verify entry date, status, document or ID numbers, and identifying information. See: Verify Lawful Presence Business Process REASONABLE OPPORTUNITY: If citizenship or satisfactory immigration status cannot be verified within the 45-day application processing time frame, the state must provide a 90-day reasonable opportunity period to allow an individual who has made a signed declaration of citizenship or satisfactory immigration status, and the state has not been able to verify with electronic sources, is allowed so the client can either provide proof of U.S. citizenship, national status, or satisfactory immigration status, or to provide evidence that they are trying to obtain that proof (such as providing a copy of the application requesting their birth certificate from another state). Reasonable opportunity is also allowed when a new immigration status is reported. The individual must respond to the initial request for verification of information and inform the state that they need additional time to complete the request if they are unable to provide the documentation. If the requested information is not returned, Medicaid is denied. The 90-day period starts when the person receives the notice requesting verification, which is 5 days after it is mailed. If the person is otherwise eligible, Medicaid coverage begins on the first day of the application that includes their statement about citizenship or immigration status. During the reasonable opportunity period, the state must continue efforts to complete verification of the individual's citizenship or satisfactory immigration status, or request documentation if necessary. If satisfactory proof of U.S. citizenship or immigration status is not provided by the end of the reasonable opportunity period, Medicaid coverage is closed, with timely notice provided.

Effective Date: 7/1/2026