Exception to Rule (ETR) process due to inability to provide citizenship and/or verification

Revised date
Purpose statement

This section is additional information for Home and Community Services (HCS) cases if the applicant or recipient cannot provide evidence of U.S. citizenship or identity. An exception to rule can be requested in limited circumstances.

HCS ETR process regarding citizenship or identity verification requirements

This section gives additional information on processes as the information indicated in the citizenship and identity requirements for medicaid.

If the applicant or recipient cannot provide evidence of U.S. citizenship or identity, an exception to rule (ETR) can be requested in limited circumstances. These are individuals that attest to being a U.S. citizen but have been unable to provide verification.

Examples for an ETR include but are not limited to:

  • Amnesia or coma victim
  • Individual with a dire medical condition whose life will be in jeopardy without medical care.
  • An individual needing services provided by Home and Community Services (HCS).

New applications are denied if citizenship or identity documents cannot be provided. Pend the application if an ETR is appropriate.

For recipients where, requested verification for citizenship or ID have not been provided, keep the case open and request an ETR if appropriate.


Health Care Authority (HCA) has requested that All ETR requests from HCS go through Lori Rolley at HCS Headquarters. HCS field staff need to email Lori Rolley Lori.Rolley@dshs.wa.gov with the following information:

  • Subject line: "ETR citizenship/ID requirements".
  • Include the client's name and client id in the text of the e-mail.
  • Indicate whether the individual is at living at home, in residential or in a nursing home.

Lori will forward all ETR requests from HCS to the HCA policy representatives. A response from HCA will be forwarded back to the originator of the request.

Worker Responsibilities

At each review, make sure the correct citizenship and ID coding is updated in ACES. 

For individuals that are receiving Medicare, SSI (or past SSI) or SSA disability based on their own disability:

  • If there is no T1 or T2 document in the case record, indicate the citizenship coding as T4.

The following are acceptable identity documents:

  • A current state driver license with the individual's picture.
  • A state identity card with individual's picture.
  • A US American Indian/Alaska Native tribal document.
  • Military identification card with individual's picture.

For disabled individuals in residential care facilities the facility administrator or director may submit affidavits attesting to the individual's identity.