01.01.03 - Citizenship Status of the Child

Effective Date: 08/07/08
Revision Date: 12/16/08, 04/01/17

Reference: Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996, P.L. 104-193, as amended; Federal Register notices 62 FR 61344 (November 17, 1997), 63 FR 41658 (August 4, 1998), and 63 FR 41662 (August 4, 1998); ACYF-PI-CC-98-08; CCDF-ACF-PI-2008-01 (May 2, 2008), and 45 CFR, Subpart C, §98.20

Policy Statement:

Title IV of PRWORA requires programs offering Federal public benefits to verify the citizenship and immigration status of the recipients of such services. The Child Care and Development Fund is considered a program that provides a Federal public benefit and is subject to the verification requirement. 

The citizenship status must be verified unless the child is exempt from verification requirements. A child enrolled in a Head Start or Pre-K collaboration is exempt from the verification requirements. However, if a Head Start grantee operates a separate program that is entirely supported by CCDF funds, the separate CCDF program is not exempt from the verification requirements.

Federal Funds: Citizenship and immigration status of the child, the primary beneficiary of Child Care and Development Fund (CCDF), is relevant for the purposes of establishing a payment funding source. Federal funds may be utilized for payments of eligible U.S. citizens, U.S. non-citizen nationals, and qualified aliens.

State Funds: Federal funds cannot be used to pay for eligible care for a non-citizen child who is not a qualified alien (see definition below).A non-citizen child who does not meet criteria as a qualified alien includes undocumented or illegal immigrants as well as immigrants, formerly considered eligible for benefits by the courts, known as Permanent Residence Under Color of Law "PRUCOL".

Illinois will continue to authorize services to non-citizen children and will pay for these services with State dollars.

Eligibility for the Child Care Assistance Program:

  • Citizenship or immigration status of the child's parent cannot be considered and will not impact the child's eligibility determination.
  • Eligibility will not be denied based on a child's citizenship status


The law regarding U.S. citizenship and nationality is complex; therefore the following are broad definitions for general guidance only. If additional clarifications are necessary, please contact the Bureau of Child Care and Development Program Policy Manager.

United States citizen: (1) A person (other than the child of a foreign diplomat) born in one of the several States or in the district of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, or the Northern Mariana Islands who has not renounced or otherwise lost his or her citizenship; (2) A person born outside of the United States to at least one U.S. citizen parent (sometimes referred to as a "derivative citizen") or (3) a naturalized U.S. citizen.

United States non-citizen national: a person born in an outlying possession of the United States (American Samoa or Swain's Island) on or after the date the U.S. acquired the possession, or a person whose parents are U.S. non-citizen nationals (subject to certain residency requirements).

Qualified Alien: An alien lawfully admitted for permanent residence under the Immigration and Nationality Act (INA). I ncludes lawful permanent residents, asylees, refugees, parolees, individuals granted withholding of deportation or removal, conditional entrants, Cuban or Haitian entrants, battered aliens, and alien victims of a severe form of trafficking. The term qualified alien is not itself an immigration status, but includes a collection of immigration statuses. It is a term used for Federal public benefits purposes.


  1. Applicant Responsibility
    1. An applicant shall attest to the citizenship status of each child by completing Section 3 - Family Information of the Child Care Application (Form IL444-3455). If the child is a qualified alien, the parent must provide the alien registration number and submit supporting documentation.
    2. The applicant must declare under penalty of perjury and possibly subject to later verification of status, that the child is a U.S. citizen, U.S. non-citizen national or qualified alien. The parent's signature obtained in Section  8 - Parent/Guardian Certification of the Child Care Application that includes the child for whom care is requested is sufficient to meet this criteria.
  2. Staff Responsibility
    1. The citizenship status of each child for whom care is requested must be verified and appropriately coded in the Child Care Management System or CCMS.
      1. Qualified Child
        A child who is a U.S. citizen or U.S. non-citizen national or qualified alien is identified in ACID with the following codes: 30, 31, 34, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 71, 72, 73, 81 or 82.
      2. Non-Qualified Child
        A child who is a "non-qualified" immigrant or who is undocumented is identified in ACID with the following codes: 36, 37, 38, 39, 42 or 55.
      3. Status Unknown
        A child whose status is unknown may have one of the following codes in ACID: 32, 33, 35, 43, or 44. If either the declaration, documentation, or signature is not received, the child shall be considered non-qualified. 
    2. If the case has no connection to TANF, SNAP, or Medical assistance programs the following procedures apply: 
      1. Qualified child
        If the case is otherwise eligible, care may be approved for this child.
      2. Non-Qualified Child
        Do not Request Additional Information or otherwise delay processing the application for this information.
      3. Head Start/Pre-K Collaboration
        A child who is no longer enrolled in a Collaboration program must document their status as a United States citizen, United States non-citizen national, or a Qualified Alien if care is needed with a non-collaboration provider.