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verification of citizenship is acceptable proof of citizenship, if verification was obtained
for the other program. As indicated above under the discussion of verification of alien
eligibility, DOJ also has provided guidelines for verification of citizenship. Therefore,
we proposed to remove the verification guidance in current paragraph (f)(2)(ii) and
provide in new paragraph (f)(2)(ii) that State agencies must verify citizenship in
accordance with the DOJ guidance if a household member's citizenship status is
questionable.
State agencies and advocacy groups generally supported the proposal to verify a
statement of citizenship only when questionable. Several advocacy groups asked the
Department to restore a deleted provision allowing a declaration from a citizen that the
household member in question is a citizen. One State agency felt that the Department
should not adopt by reference unpublished DOJ rules which might impose burdensome
verification requirements on State agencies. The same State agency suggested that the
Department allow State agencies to accept statements of parents on behalf of children
who as minors obtained derivative citizenship when their parents naturalized. The State
agency observes that many individuals cannot produce documentation of this category of
derivative citizenship as the INS documents cost $160.
In response to comments, we are modifying the proposed language to add a
requirement to verify the non-citizen national status of individuals whose status is
questionable, in addition to the existing requirement to verify the U.S. citizenship of
individuals whose citizenship is questionable. The addition conforms to the final
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"ocrText": "verification of citizenship is acceptable proof of citizenship, if verification was obtained\nfor the other program. As indicated above under the discussion of verification of alien\neligibility, DOJ also has provided guidelines for verification of citizenship. Therefore,\nwe proposed to remove the verification guidance in current paragraph (f)(2)(ii) and\nprovide in new paragraph (f)(2)(ii) that State agencies must verify citizenship in\naccordance with the DOJ guidance if a household member's citizenship status is\nquestionable.\nState agencies and advocacy groups generally supported the proposal to verify a\nstatement of citizenship only when questionable. Several advocacy groups asked the\nDepartment to restore a deleted provision allowing a declaration from a citizen that the\nhousehold member in question is a citizen. One State agency felt that the Department\nshould not adopt by reference unpublished DOJ rules which might impose burdensome\nverification requirements on State agencies. The same State agency suggested that the\nDepartment allow State agencies to accept statements of parents on behalf of children\nwho as minors obtained derivative citizenship when their parents naturalized. The State\nagency observes that many individuals cannot produce documentation of this category of\nderivative citizenship as the INS documents cost $160.\nIn response to comments, we are modifying the proposed language to add a\nrequirement to verify the non-citizen national status of individuals whose status is\nquestionable, in addition to the existing requirement to verify the U.S. citizenship of\nindividuals whose citizenship is questionable. The addition conforms to the final"
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