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Page 14 – State Health Official Letter Hub VLP Service v37.1, Version 2 The Hub interprets the immigration codes received from SAVE to help states determine Medicaid and CHIP eligibility based on qualified noncitizen status under PRWORA and lawful presence status for purposes of the CHIPRA 214 option. The Hub currently transmits indicators to states reflecting the following: • citizenship (for individuals with naturalized or derived citizenship); • lawful presence (used for Marketplace53 and the CHIPRA 214 option); • qualified noncitizen; • if the five-year waiting period is applicable (only for qualified noncitizens); • if the five-year waiting period is met (only for qualified noncitizens, when applicable); and • the underlying immigration codes received from SAVE. The Hub will continue to transmit to states all current indicators, listed above, as these indicators will not be impacted by implementation of section 1903(v)(5) of the Act. In 2026, in addition to the current indicators, the Hub will transmit a new indicator to states reflecting FFP-eligible noncitizen status for full Medicaid and CHIP benefits in accordance with sections 1903(v)(5) and 2107(e)(1)(R) of the Act for each noncitizen verified by the Hub. See the following examples of Hub responses with the new indicator: • When a state submits a verification request for an asylee, the Hub would return: o “Yes” for qualified noncitizen status indicator, o “No” for eligible noncitizen54 status indicator, o “No” for whether the five-year waiting period is applicable, and o “Not Applicable” whether the five-year waiting period has been met. • When the state submits a verification request for an LPR, the Hub would return: o “Yes” for qualified noncitizen status indicator, o “Yes” for eligible noncitizen status indicator, o “Yes”/“No” for whether the five-year waiting period is applicable (depending on whether the individual met an exception from the five-year waiting period), and o “Yes”/“No”/“Not Applicable” for whether the five-year waiting period has been met. See Appendix B for a summary of the Hub changes to verify FFP-eligible noncitizen status, including the applicable ESCs, COA codes, and EAD Category codes returned by SAVE.

53 Similar to the FFP limitations added by section 71109, section 71301 of the WFTC legislation added limits on eligibility for premium tax credits to noncitizens who are “eligible aliens” (i.e., LPRs, Cuban/Haitian entrants, and COFA migrants), beginning January 1, 2027. 54 The Hub will use a simplified term of “eligible noncitizen” for the new indicator, which has the same meaning as the “FFP-eligible noncitizen” term used in this letter (i.e., LPRs, Cuban/Haitian entrants, and COFA migrants).