A Overview

Revised 04/22/2025

Policy

To qualify for full AHCCCS Medical Assistance (MA) coverage, a noncitizen must:

• Be in a qualified noncitizen status;

• For certain qualified noncitizens, meet conditions in MA524B; and

• Declare his or her qualified noncitizen status. The customer must be listed as having a qualified noncitizen status on the application, and the application must be signed by the customer or other person listed in MA1301A.

Otherwise, the noncitizen can only get coverage for Federal emergency medical services (FES) through the Federal Emergency Services Program (FESP), and cannot qualify for the following categories:

• AHCCCS Freedom to Work (FTW)

• Breast and Cervical Cancer Treatment Program (BCCTP)

• Arizona Long Term Care System (ALTCS)

• Medicare Savings Program (MSP)

• KidsCare

• Continued Coverage (CC)

• Transitional Medical Assistance (TMA)

 

Reasonable Opportunity Period

When a customer claims a qualified noncitizen status, but more proof is needed to verify it through SAVE VIS or VLP, the person has a reasonable opportunity period of 90 days from the date the proof is requested to provide the proof or resolve the issue with USCIS. During this time, when the person meets all other eligibility requirements, MA is approved as a conditional approval.

NOTE     The child's coverage can be terminated if they do not supply the required citizenship/non-citizenship status documentation within the reasonable opportunity period. If the status is verified, the child's continuous eligibility period will be effective with the effective date of coverage.

There is no limit on the number of reasonable opportunity periods a customer may receive a conditional approval.

 

Definitions

Term	Definition
Noncitizen	A person who is not a citizen or national of the United States (U.S.).
Non-qualified noncitizen	A noncitizen who does not have a qualified immigration status.
Qualified noncitizen	A person admitted to the U.S. in one of the immigration statuses in the list below: Afghan and Iraqi Special Immigrant Visa Deportation Withheld or Removal Withheld (this does not include Deferred Action for Childhood Arrivals or “DACA” status) Amerasian Refugee Asylee Battered noncitizen (must also meet conditions in section B) Citizens of the following Compact of Free Association (COFA) countries: Republic of the Marshall Islands Federated States of Micronesia Republic of Palau Conditional Entrant Cuban-Haitian Entrant Hmong or Laotian Highlander Lawful Permanent Resident (LPR) (must also meet conditions in section B) Parolee for at least one year (must also meet conditions in section B) Refugee Victims of Trafficking (as of the eligibility date in the certification letter issued by the Office of Refugee Resettlement).
Parolee	A noncitizen who has received a grant of parole into the United States for a temporary period of time because of urgent humanitarian needs or significant public benefit.
Reasonable Opportunity Period (ROP)	A 90-day period where individuals can provide documentation to verify their citizenship or immigration status if it's not initially verified through electronic means, allowing them to maintain eligibility while the verification is pending.
American Indian Born in Canada	An American Indian with at least 50% Indian ancestry born in Canada is considered a qualified noncitizen. NOTE     A person in this group may choose to become an LPR. This does not affect the status as an American Indian born in Canada. The person does NOT need to meet the other conditions in section B.
Foreign Born Member of U.S. Indian Tribe	A member of a federally recognized U.S. Indian Tribe who does not claim U.S. citizenship. People in this group are considered qualified noncitizens. NOTE     For federally recognized U.S. Indian Tribes see the annual list published in the Federal Register.

 

Proof

For most qualified statuses, a SAVE VIS or VLP response showing a qualified status. If unable to verify the person’s status through the initial SAVE VIS or VLP response, the following documents can be used to resubmit the SAVE or VLP request:

• Permanent Resident or Resident Alien Card, I-551;

• Alien Registration Receipt Card, I-151;

• Departure Record, I-94;

• Employment Authorization Card, I-766;

• Foreign Passport;

• Parole Notice;

• Form I-512L, Authorization to Transport for Parole of an Alien Into the United States

• Approved Petition for Amerasian, Widow(er), or Special Immigrant, Form I-360;

• Certificate of Residency or Naturalization for citizens of the Marshall Islands;

• Certificate of Residency or Naturalization for citizens of the Federated States of Micronesia;

• Certificate of Residency or Naturalization for citizens of the Republic of Palau

 

Additional proof is needed when:

1) The customer is a spouse, child, parent, or legal guardian of an Afghan paroled between 7/31/2021 and 9/30/2023.

• Expired or unexpired Afghan passport that lists the person’s place of birth as being Afghan; or

• Afghan birth certificate

• Nationality certificate

• Citizenship letter

 

2) The customer is a spouse, child, parent, legal guardian, or primary caretaker of a Ukrainian paroled between 2/24/2022 and 9/30/2024.

• Expired or unexpired Ukraine passport that lists the person’s place of birth as being Ukraine; or

• Ukraine birth certificate

• Nationality certificate

• Citizenship letter

 

Exception:

The following exceptions cannot be verified through SAVE VIS or VLP and will require additional proof. 

If the customer is...	Then the required proof is...
Victims of Trafficking	Victim of Trafficking Certification Letter or Eligibility Letter
Battered Noncitizen	A notice of "prima facie" approval of a pending self-petition under the Violence Against Women Act (VAWA)
Deportation/removal withheld under Section 243(h) of the Immigration and Nationality Act (INA) or whose removal was withheld under Section 241(b)(3) of the INA	Form I-766 annotated "A10." A copy of the order from an immigration judge showing deportation withheld under Section 243(h) of the INA as in effect prior to 4/1/97 or removal withheld under Section 241(b)(3) of the INA. A letter from an asylum officer granting withholding of deportation under Section 243(h) of the INA as in effect prior to 4/1/97 or withholding of removal under Section 241(b)(3) of the INA.

 

Legal Authority

Program	Legal Authorities
All programs	8 USC 1611, 1612, 1613, and 1641 42 CFR 435.406(a) 42 CFR 435.911(c) and 956(b)(2) 42 CFR 435.949 and 956(a)(1)(i) AAC R9-22-305.4 AAC R9-28-401.01(B)1 AAC R9-29-204.3 AAC R9-31-302(A) 42 CFR 457.320(b)(6)