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Draft County Letter for DRA Citizenship Requirements

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To all Stakeholders:

As many of you are aware, the federal Deficit Reduction Act requires the State of California to implement verification of documentation of citizenship and identity for all applicants for and people on the Medi-Cal program who declare that they are citizens of the United States.  The only exceptions allowed by federal regulation are people who receive SSI or who are on Medicare.  Federal regulations were issued on July 6, 2006 and provide the basis for the implementation of this federal requirement.  AB 1807, which in part implements this federal requirement, requires that the California Department of Health Services seek comments on this All County Welfare Directors Letter (ACWDL) before the Department issues it. 

The draft ACWDL provides instructions to counties on the implementation of the new federal rules and state law regarding documentation of citizenship and identity for all applicants and beneficiaries on Medi-Cal.  We are sending this draft letter to approximately 1100 stakeholders which are comprised of individuals from the following: advocate organizations, counties, health providers, health plans, state associations, state boards, other state departmental staff, some private citizens (those who have requested to be on lists maintained by the state for such efforts), and legislative staff.

Given the tight timeframes provided in federal law, we are asking for an expedited review.  Please respond with any comments no later than July 28, 2006.  We ask that you clearly delineate any changes or comments you have on this document.  If you desire to provide an edited version of this document in your response, you must use the track changes feature to clearly show your comments

Please direct all responses on this letter to the special email inbox that we have established for this purpose:

[email protected]

You may also find this letter and other relevant documents from the federal government on this matter at the following CDHS website:


  • Still treats applicants different than beneficiaries.  As per the fed guidance, eligibility will not be determined until documentation of citizenship is acquired.  Beneficiaries will continue to receive Medi-Cal as long as they are making a “good faith effort” to provide documents.  Applicants have 45 days (or 90 if disability determination required) but this may be extended if showing a “good faith effort” to obtain documentation.
  • “Good faith effort” means effort to obtain and present documentation is demonstrated, included evidence of identity if applicable.  There is a request for assistance for assistance with this definition from stakeholders.
  • Vital statistics matches will be sought for all CA-born residents, but no agreement with other states at this time for matches for non-CA-born residents.  Those whose citizenship is documented by a data match will need to document their identity.  State birth records will be checked for all applicants and beneficiaries beginning August 2006.
  • Documentation not required for presumptive eligibility or accelerated enrollment, but documentation will be required for ongoing eligibility determination.  Prenatal services through the Minor Consent Program do require documentation, but not through other prenatal programs.
  • SSI & Medicare beneficiaries excluded from this rule.
  • If an individual is otherwise eligible, but cannot meet the documentation requirement, that person will receive restrictive Medi-Cal services only.
  • Citizenship/identity documents do not need to be provided in-person.  However, in most cases documents submitted must be originals, even if mailed in.  Counties are advised to set up special handling units to ensure that documents are not lost.
  • Counties are not required to pay for documents and the state will not reimburse them if they do.  The steps for “assisting” an applicant or beneficiary obtain documentation consist mainly of search CA gov benefits databases, checking existing county files and an SB-87-like redetermination process.  Language of the notices are included.  Counties must assist persons who are incapable of providing their own documentation due to impairments, but this is not further explained.
  • Parents, including noncitizen parents, may provide affidavits for citizen children under 16 to show identity if no other documentation is available and an affidavit was not used to prove citizenship.  Noncitizen parents cannot provide an affidavit for citizenship of their children as only citizens may do a tier 4 affidavit.
  • Title IV-E foster care children are treated as beneficiaries and considered eligible upon their entry into the Medi-Cal program but are not otherwise exempted from these requirements.
  • CalWORKs, PCSP, and IHSS+ waiver recipients (unless also SSI and/or Medicare) are not exempted but these files must be checked to verify is evidence of citizenship was ever presented.
  • The state’s outreach plan is included, but there is nothing exceptional – mainly notices, posters, and information for counties and providers.  Counties are required to “alert Medi-Cal applicants and beneficiaries as soon as possible” mainly through the notices provided by the state.
  • The notices are included for review.

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