PM 03-01-08
Verify Lawful Presence (VLP) for Documented Non-Citizens
Non-citizen status must be reviewed at initial application 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 the Data Exchange the result will show in a pop-up box like 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 (Class of Admission) Code 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.
Non-Citizen Details Page
When an adult or a child applies for medical coverage and the individual states that they are an undocumented non-citizen and there is not a reason to request further information from the individual, then enter undocumented on the Non-Citizen - Details page. When an individual has stated they are documented or has provided documentation for their immigration status, enter documented on the Non-Citizen - Details page. Verify lawful presence for each documented non-citizen requesting medical coverage.
Non-Citizen Admission Status Field
The Non-Citizen Admission Status field contains the following four dropdown options:
- Documented,
- Undocumented,
- Unknown, and
- Pending (10 days).
Select the status as identified by each individual.
See WAG 03-01-09 for Undocumented, Unknown and Pending (10 days).
Documented Non-Citizen
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 Non-Citizen Type / Document,
5. select Non-Citizen Type Verification, and
6. enter the Alien Registration Number.
The next step is to verify lawful presence details for the documented non-citizen. To trigger the VLP details, select the V icon symbol on the top of the Non-Citizen - Details page. Once the V icon has been selected, the VLP clearance is invoked and the Lawful Presence Details window opens.
Complete the following fields:
- Alien Number; and
- Document Type.
Select Next to submit the entered information to the Federal Data Services Hub.
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.
Note: Complete the Additional Verification process when the VLP request is unsuccessful (see WAG 03-01-06-d).
Documented Non-Citizen (Documentation 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.
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 (10 days) 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.
Note the actions taken in case comments.
Qualified Immigration Status Pending (90 days)
Federal regulations require that individuals are given 90 days to prove their immigration status when an applicant reports they are documented, they have a Medicaid qualifying status and the applicant meets all other eligibility criteria. Medicaid qualifying immigration statuses 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 response. No response after 90 days will result in loss of benefits.
Note the actions taken in case comments.
Verification Checklist (VCL)
VCL Scenarios: When should I request additional information related to non-citizen status?
Common scenarios that would 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 of the USCIS 'A' number.
- 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.
Note the actions taken in case comments.
NOTE: Not responding to a VCL for citizen/noncitizen information does not indicate that an individual is undocumented.
