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New Identity and Citizenship Regulations

MPLP Summer 2007 Public Benefits Section Newsletter Article

                Issue 34, Summer 2007

New Identity and Citizenship Regulations

by Lisa Ruby, MPLP Public Benefits Attorney


As part of the Deficit Reduction Act of 2005, states are requiring applicants and ongoing recipients of Medicaid to prove citizenship status using original documents.  The result is that these requirements that began July 1, 2006, have cost health centers $28 million to $85 million and 2.2% to 6.7% of their 4.8 million Medicaid enrollees.  These were the reported results of an online survey released last month by the George Washington University School of Public Health and Health Services. Responses came in from 139 of the 300 federally qualified health centers surveyed. There are 952 such facilities in the United States.

Here in Michigan, these new regulations went into effect on April 1, 2007.  Thus far there has not been a huge deluge of application denials or termination of benefits.  However, it is still early in the process with the majority of recipients not yet having been asked to provide this information as they have yet to go through their annual redetermination.  Some recipients will not be subject to this requirement as their records will show up in the data matching system being used by the state.  For individuals who were born in Michigan, that information is already on record.  However, technical difficulties may still be lurking around the corner.  In Kansas, which implemented its own record-matching system, 20,000 people have been dropped from the Medicaid rolls as of March, 2007.  It typically takes about eight weeks to obtain a birth certificate from another state.  In Ohio, which only allows 45 days for enrollees to obtain documentation, enrollment has dropped by 39,000.  In Michigan, the vast majority of low-income children (91%) and adults (79%) were born here, so an effective data-matching system will go a long way in running an efficient program.

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