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    v1.0.28
    OpenPayerPolicy UpdatesAdministrative/Operational PolicyIndiana DOI Ukraine Immigrant Coverage | OpenPayer
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    CurrentIndiana Department of InsurancePolicy 2402.20.60

    Ukraine Special Immigrants

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    This policy governs Medicaid and CHIP eligibility for Ukrainian nationals, non-Ukrainian individuals who last habitually resided in Ukraine, Ukrainian parolees, and individuals with Temporary Protected Status or related immigration classifications. It explains qualified non-citizen requirements, five-year-bar exceptions, acceptable verification, retroactive coverage, and the 90-day reasonable opportunity period.

    Policy Summary
    PayerIndiana Department of Insurance
    PolicyUkraine Special Immigrants
    Policy CodePolicy 2402.20.60
    Change TypeRevised
    Effective DateOctober 1, 2026
    Next Review DateNot specified
    Key ActionWhen immigration status cannot be verified promptly, determine eligibility during the 90-day reasonable opportunity period if the individual attests to an eligible status and meets all other requirements.
    SourceLink
    POLICY UPDATE CHANGES

    Eligibility for specified Ukraine special immigrants and parolees was revised so that full-coverage Medicaid generally requires adjustment to a qualified non-citizen status or satisfaction of a federal exemption.

    90 daysReasonable Opportunity Period
    5-year barFive-year waiting period
    6Humanitarian parole verification indicators

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    2/24/2022–9/30/2023Special parolee entry window

    Eligibility and Coverage Requirements

    Ukraine Special Immigrant or Parolee Eligibility

    Effective October 1, 2026, full-coverage Medicaid or CHIP may be available to qualifying Ukraine-connected immigrants and parolees when the applicable immigration and program requirements below are met.

    ALL of the following

    • ONE of the following Ukraine-connected populations

      • A citizen or national of Ukraine who has special immigrant status under section 401 of the Immigration and Nationality Act (INA).
      • A person who is not a Ukrainian citizen or national but last habitually resided in Ukraine and has qualifying special immigrant status.
      • A Ukrainian national or a person who last habitually resided in Ukraine who entered the United States as a parolee between February 24, 2022, and September 30, 2023.

    • ONE of the following immigration conditions

      • The individual has adjusted to a qualified non-citizen status under 2402.20.00.
      • The individual meets a federal exemption from the qualified non-citizen requirements.
    • The individual meets all other applicable Medicaid or CHIP eligibility requirements.

    Qualified Status or Federal Exemption

    Full-coverage eligibility depends on qualified non-citizen status or an applicable federal exemption. Immigration status alone does not establish eligibility when the individual has not met the applicable conditions.

    Temporary Protected Status (TPS) limitation

    • A Ukrainian national granted TPS only, or with a pending TPS application, is considered lawfully present but is not a qualified non-citizen.
    • The individual must adjust to a qualified non-citizen status and is subject to the five-year waiting period unless an applicable federal exemption applies.
    • Acceptable verification may include an Employment Authorization Document (EAD) with category A12 or C19, Form I-797, an application for temporary protected status, or other verification or documentation from DHS or another authoritative source.

    Retroactive Coverage

    Retroactive coverage may be provided for an otherwise eligible Ukraine special immigrant or parolee when the applicable retroactive eligibility requirements are satisfied.

    ALL of the following

    • The individual is eligible for full-coverage Medicaid or CHIP under the applicable Ukraine special immigrant or parolee rules, including adjustment to a qualified non-citizen status or satisfaction of a federal exemption when required.
    • All other eligibility requirements are met for the retroactive period, including income and residency requirements.
    • The requested retroactive period is supported by the individual's eligibility; the eligibility date may or may not coincide with the special immigrant's date of entry.

    Reasonable Opportunity Period

    Use the reasonable opportunity process when immigration verification is delayed but the individual attests to an eligible immigration status and otherwise qualifies.

    ALL of the following

    • The worker is unable to promptly verify the Ukrainian national's immigration status.
    • The individual has attested to having an eligible immigration status.
    • The individual meets all other Medicaid eligibility requirements.
    • The individual is determined eligible for Medicaid during the 90-day reasonable opportunity period.90 days

      Refer to 2035.40.05 for processing guidelines. Submit a PAL for questionable eligibility or immigration status.

    Key Eligibility Parameters

    Reasonable Opportunity Period
    Period90 days
    When usedWhen immigration status cannot be promptly verified
    ConditionsThe individual must attest to an eligible immigration status and meet all other eligibility requirements
    Five-Year Waiting Period
    ApplicabilityApplies to certain qualified non-citizens who are subject to the five-year waiting period
    Ukraine special immigrantsUkraine special immigrants who adjust to lawful permanent resident status are exempt from the five-year bar
    Special immigrant parolees

    Verification and Processing Actions

    Documentation Required

    Verify humanitarian parole documentation

    Verify humanitarian parole with one of the specified documents or status indicators before determining eligibility.

    • Form I-94 noting humanitarian parole under INA section 212(d)(5) or 8 U.S.C.
    • A foreign passport with a DHS/CBP admission stamp noting “DT,” “Uniting for Ukraine” or “U4U,” or “Ukrainian Humanitarian Parolee” or “UHP.”
    • Form I-765 EAD receipt notice or Form I-766 EAD with code C11.
    Documentation Required

    Verify TPS status or application

    Accept specified evidence for Temporary Protected Status or a pending TPS application. Ukrainian nationals granted TPS or with a pending TPS application are considered lawfully present but are not qualified non-citizens.

    • EAD with category A12 or C19.
    • Form I-797, Application for Temporary Status.
    • Verification or documentation from DHS or another authoritative source.

    Immigration and Processing Terms

    Ukraine Special Immigrant
    Eligible individualA citizen or national of Ukraine, or a person who last habitually resided in Ukraine
    Entry classificationMay enter the United States as a lawful permanent resident with a special immigrant visa
    Alternative pathwayMay adjust to special immigrant status after entering the United States under another immigration status, such as asylee or parolee
    Temporary Protected Status
    Who may applyUkrainian nationals and individuals with no nationality who last habitually resided in Ukraine, continuously resided in the United States since April 11, 2022, and were continuously physically present since April 19, 2022
    Qualified statusTPS recipients and individuals with a pending TPS application are lawfully present but are not qualified non-citizens
    Policy Summary
    PayerIndiana Department of Insurance
    PolicyUkraine Special Immigrants
    Policy CodePolicy 2402.20.60
    Change TypeRevised
    Effective DateOctober 1, 2026
    Next Review DateNot specified
    Key ActionWhen immigration status cannot be verified promptly, determine eligibility during the 90-day reasonable opportunity period if the individual attests to an eligible status and meets all other requirements.
    SourceLink
    On This Page
    Eligibility and Coverage RequirementsKey Eligibility ParametersVerification and Processing ActionsImmigration and Processing Terms
    Special immigrant parolees who adjust to lawful permanent resident status are exempt from the five-year bar
    Billing Rule

    Apply the 90-day reasonable opportunity period

    If immigration status cannot be verified promptly, determine the person eligible during the 90-day reasonable opportunity period when the individual attests to an eligible immigration status and meets all other eligibility requirements.

    • Confirm the individual’s attestation to an eligible immigration status.
    • Confirm that all other eligibility requirements are met.
    • Apply the 90-day reasonable opportunity period while verification is pending.
    Denial Risk

    Submit a PAL for questionable eligibility

    Submit a PAL when eligibility or immigration status is questionable.

    • Escalate questionable eligibility.
    • Escalate questionable immigration status.
    Medicaid treatmentThey must adjust to a qualified non-citizen status and are subject to the five-year waiting period unless an exception is available
    Special Immigrant Parolee
    Eligible classificationA Ukrainian national or a non-Ukrainian individual who last habitually resided in Ukraine and entered the United States as a parolee
    Entry periodThe individual must have entered on or between February 24, 2022, and September 30, 2023
    Adjustment requirementFull-coverage Medicaid or CHIP requires adjustment to a qualified non-citizen status or satisfaction of a federal exemption
    Five-year-bar exceptionThose who adjust to lawful permanent resident status are exempt from the five-year bar
    Reasonable Opportunity Period
    PurposeA temporary period for determining Medicaid eligibility while immigration status is being verified
    TriggerThe individual attests to having an eligible immigration status, but the status cannot be verified promptly
    Eligibility requirementsThe individual must meet all other eligibility requirements