MR #24.07 Verify Lawful Presence (VLP) and the SAVE Clearance

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02/13/2025

Summary:

This manual release provides guidance for:

Identifying the non-citizen details located on medical applications.
The importance of entering the correct Circumstance Start Change Details (CSCD).
Clearances used for non-citizen status.
Using the SAVE system.
Clearance Results page.
Entries made to the Non-Citizen - Details page.
When to send a Verification Checklist (VCL).
Entering available non-citizen documentation even when it is not required.
Proof of citizenship or identity for recipients of Medicare.
U.S. Passport issued to a person born in Puerto Rico.

Immigration Status at Application and During Redetermination
Application for Medical Benefits
Circumstances Start / Change Date (CSCD)
What Clearances may be used to validate non-citizen status?
1. Verify Lawful Presence (VLP) in IES
2. Web-based Systematic Alien Verification for Entitlements (SAVE)
Clearance Results Page
Non-Citizen Details Page
1. Non-Citizen Admission Status Field
  1. Documented Non-Citizen
Verification Checklist (VCL)
1. VCL Scenarios: When should I request additional information related to non-citizen status?
Policy Clarification
IES Wizards
MANUAL REVISIONS

Immigration Status at Application and During Redetermination

Non-citizen status must be reviewed at initial application and at redetermination.

Why is the non-citizen status type so important?

Eligibility is determined using this information. Entries must be accurate for the system to correctly determine an individual's eligibility for medical programs.
Services limited to undocumented non-citizens such as emergent medical are included in benefit plans available to documented non-citizens.
Medical Program funding;
- Most medical programs are jointly funded by the state and federal governments. However, that is not true for all. It is important that documented non-citizens are identified correctly so that funding sources are accurate.

Application for Medical Benefits

Application for Benefits Eligibility (ABE)

Review the ABE application for the following details provided by the applicant:

Social Security Number (SSN),
SSN Application Date,
US Citizen?,
Date of Entry into US,
Is this person a documented non-citizen?,
Status Begin Date,
Requesting emergency medical for a non-citizen?,
Document Number,
Non-Citizen Registration Number,
Document Type,
Has this person applied for, or do they intend to apply for, Asylum?,
Has this person applied for, or do they intend to apply for, a T Visa? and
Has this person applied for, or do they intend to apply for, a U Visa?.

ABE application screen shot.

Federally Facilitated Marketplace (FFM) Application

Review FFM applications for the following details provided by the applicant:

Social Security Number (SSN),
SSN Application Date,
US Citizen?,
Date of Entry (if documented alien),
Is this person a documented alien?,
Document Type,
Document Number and
Alien Registration Number.

FFM Application example.

Paper Application

Review the 2378B (Paper) Application for the following details provided by the applicant:

Are all persons U.S Citizens?
Name,
Age,
Arrival Date in the United States, and
Registration document/number.

Circumstances Start / Change Date (CSCD)

It is very important to enter the correct CSCD when entering non-citizen information. The CSCD is used when determining the effective date for an individual's eligibility for programs. If an individual's status changes (undocumented to documented, lawfully present to LPR, etc.) the dates must be updated appropriately to keep accurate historical information and to ensure the individual will be put in the correct program.

What Clearances may be used to validate non-citizen status?

Verify Lawful Presence (VLP) in IES

The VLP clearance is used when the USCIS (A) number and document number is provided. This is the primary clearance and should be used whenever possible.

Note: The eleven digit number denoted on an I-94 Entry/Departure Record is not the same as the Alien Registration Number (A#).

The VLP clearance is available in the following locations in IES:

Clearance Results page,
Non-Citizen - Details page, and
Data Exchange page.

The Verify Lawful Presence Details page provides information about non-citizens based on their alien number such as:

Country of Birth,
Country of Citizenship at their Entry Date,
Document Type,
Grant Date,
Class of Admission (COA) Code, and
Five Year Bar Met Indicator.

Web-based Systematic Alien Verification for Entitlements (SAVE)

SAVE is an online clearance used to verify non-citizen status. SAVE should only be used when:

The only information given is the USCIS (A) number,
The response from the VLP clearance is "Institute Additional Verification", or
The VLP provides the message "You have selected a value for the "Non-citizen Type/Document" that cannot be used to process this case. View document in ECR and run VLP clearance to validate provided information."

All caseworkers and managers in FCRCs have access to the VLP clearance. DHS offices have specific staff members in each office with access to SAVE so when it is necessary to use SAVE (as directed above) follow office procedures for each request. SAVE responses must be uploaded to the ECR under Document Category - Non-Financial as Document/Task Title - Proof - Citizenship. Case Comments should include the non-citizen clearance result and which clearance was used.

See PM/WAG 03-01-06 for guidance on using the SAVE system.

Clearance Results Page

When does the VLP clearance need to be run?

Non-Citizen Admission Status must be reviewed at initial application, adding an individual and at redetermination. The clearance must be revisited at redetermination to verify the status is still valid and/or to review any changes.

Whether running VLP on the Clearances page, on the Non-Citizen - Details page, or through Data Exchange, the result will show in a pop-up box shown below.

The results will include, as applicable:

1) Name, SSN, Date of Birth, Country of Birth, and Country of Citizenship.

2) Residency Case No., Alien Number, Is Five Year Bar Applicable?, Five Year Bar Met Indicator, Query Date, Document Type, and Verification Reason.

3) COA Code (Class of Admission) and Eligibility Statement.

4) Grant Date (this is the date to enter on the Non-Citizen Details page as the date of entry) and Sponsorship Information.

VLP Clearance screen shot.

Non-Citizen Details Page

Non-Citizen Admission Status Field

The Non-Citizen Admission Status field contains the following four dropdown options:

Documented (see WAG 03-01-08),
Undocumented,
Unknown, and
Pending (10 days).

See WAG 03-01-09 for Undocumented, Unknown and Pending (10 days).

Select the status as identified by the individual.

Documented Non-Citizen

Review IES Wizard Record Non-Citizen Status for guidance.

Enter the following details for documented non-citizens when the required/acceptable documents are received:

1. Circumstance Start/Change Date (CSCD) and Date Client Became Aware: enter the first day of your first month of backdate if requested or if backdate is not requested enter the first day of the application month,

2. Reported On date and Verification Received date: enter the application date,

3. Non-Citizen Admission Status: select Documented,

4. select the Non-Citizen Type / Document,

5. select the Non-Citizen Type Verification, and

6. enter the Alien Registration Number.

Non-Citizen Details page screen shot.

Next step is to verify the lawful presence details for the documented non-citizen. To trigger the VLP details, select the on the top of the Non-Citizen - Details page. Once the icon has been selected, the VLP clearance is invoked and the Lawful Presence Details window opens.

Complete the following fields:

Alien Number,
Document Type, and
Document Number.

Select Next to submit the entered information to the Federal Data Services Hub.

Verify Lawful Presence pop up screen shot.

The following fields are populated on the Non-Citizen - Details page for each successful VLP request (when applicable):

Non-Citizen Admission Status,
Nation of Origin,
U.S. Date of Entry,
Alien Registration Number,
Student and Exchange Visitor Information System (SEVIS) ID, and
Is there a Sponsor for this Non-Citizen?.

Review the entries made for accuracy and provide a summary of the actions taken in case comments.

See WAG 03-01-08.

Note: Complete the Additional Verification process when the VLP request is unsuccessful (see WAG 03-01-06-d).

Documented, and documents are not provided - Non-Citizen Admission status question is answered as documented but documentation was not provided, select Pending (10 days), a VCL is generated. Note the actions taken in case comments.

Undocumented: Non-Citizen Admission status question is answered as Undocumented: select undocumented and note in case comments that the individual has reported they are undocumented and no immigration documents were received.

Non-Citizen Details - Undocumented screen shot.

Unknown - Non-Citizen Admission status question is answered as Unknown: select Pending (10 days) when the Non-Citizen Admission Status was left blank . Note the actions taken in case comments.

Pending (10 days) - Select Pending to generate a VCL when:

the individual declared to be a documented non-citizen but did not provide enough information to verify their status through one of the clearances available, and other information is needed, or
the individual is a non-citizen but did not answer the question about documentation on the application.

Qualified Immigration Status Pending (90 days)

Federal regulations require that individuals are given 90 days to prove their immigration status when the individual has declared to be documented.

Select YES or NO next to Qualified Immigration Status Pending (90 days) to indicate if the immigration status of the individual is pending.

Select "Yes" when an applicant reports they are documented, they have a Medicaid qualifying status and the applicant meets all other eligibility criteria. Medicaid qualifying immigration status are listed in PM 03-01-02 sections b through i.

Selecting "Yes" will allow approval for medical and will send a VCL allowing 90 days for a response. No response after 90 days will result in loss of benefits.

See WAG 03-01-09 for Non-citizen Admission Status of Undocumented, Unknown and Pending (10 days).

Verification Checklist (VCL)

VCL Scenarios: When should I request additional information related to non-citizen status?

Common scenarios that require a VCL:

An individual answers "No" to being a U.S. Citizen and "Yes" to being a documented non-citizen and does not provide their USCIS (A) number. In this instance a VCL is needed for verification so we may use it to validate via clearances.
The USCIS (A) number provided is found invalid using the clearances. In this instance a VCL is needed to clarify the alien registration number discrepancy.
Additional information if requested by USCIS. A VCL may be needed so USCIS may respond accurately. This response in IES means follow up must be done using SAVE. If the information needed in SAVE to submit is not available, send a VCL to obtain it.
An individual answers "No" to U.S. citizenship but does not answer the "Are you a documented non-citizen?" question on the application. A VCL is needed to find out whether the individual is documented and obtain verification of the documented status.
The documentation provided cannot be validated. A VCL may be needed to resolve the discrepancy. Review the case record for other documentation before sending a VCL.

VCL Text.

Note the actions taken in case comments.

See WAG 03-01-08

NOTE: Not responding to a VCL for citizen/noncitizen information does not indicate that an individual is undocumented.

Policy Clarification

Clarification of Proof of Immigration Documents for Pregnant Women

When applying for Moms & Babies, pregnant women are not required to provide their Social Security Number (SSN) or proof of immigration because this information is not needed to determine eligibility. However, some women may be able to meet immigration requirements. Enter provided information when a pregnant woman includes non-citizen documents even though the documents are not required as part of her Moms & Babies eligibility.

See PM 06-09-06-c

Clarification for Recipients of Medicare

U.S. citizens receiving Medicare benefits are not required to provide evidence of citizenship or identity. Do not use the receipt of Medicare as proof of U.S. citizenship, as non-citizens may receive Medicare benefits.

An individual's citizenship status should not be changed to U.S. citizen based solely on the receipt of Medicare. Review the Federal Data Services Hub (FDSH) clearance for verification of U.S. citizenship.
Receiving Medicare can only verify U.S. citizenship if the individual declared to be a U.S. citizen as part of the request and approval process to receive Medicare.
- Send a VCL when an individual receiving Medicare benefits declares they are a U.S. citizen, but the FDSH clearance does not provide verification.

See PM 03-01-01-b.