SI 00502.113 SSI Eligibility for Compacts of Free Association (CFA) Citizens/Migrants

A. Background

On March 9, 2024, the Consolidated Appropriations Act, 2024 (P.L. 118-42) amended the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to permit SSI eligibility for aliens lawfully residing in the United States under the Compacts of Free Association (CFA) between the United States and the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau. This includes citizens of CFA nations as well as certain spouses and children (under age 21) of citizens of the Federated States of Micronesia or the Republic of the Marshall Islands, regardless of the spouse’s or child’s citizenship or nationality, provided that the Micronesian or Marshallese citizen on which the relationship is based is serving on active duty in any branch of the United States Armed Forces or in the active reserves.

These individuals are eligible for SSI if they meet all other requirements of the program, such as filing an application, having resources and monthly income below the statutory eligibility limits, and residing within one of the 50 states, the District of Columbia, or the Northern Mariana Islands.

B. Verification of SSI Alien Eligibility for CFA Citizens/Migrants

As part of the SSI application process, the immigration documentation provided by the CFA citizen/migrant must be verified via the Systematic Alien Verification for Entitlements (SAVE) system in all cases. To do so, follow instructions in SI 00502.100A. Scan legible copies of both sides of the immigration document into the electronic folder (e.g., Evidence Portal, eView). If the document includes an Alien Registration Number (ARN or A#), enter the ARN in Person Information. Return the immigration document to the claimant. After receiving the SAVE response, update the status code on the record as appropriate and store a copy of the SAVE response in the electronic folder. Once the immigration status has been verified via SAVE, continue developing other eligibility requirements, as appropriate.

1. Immigration Documentation

Customs and Border Protection (CBP) may have issued Form I-94 Arrival/Departure Record to CFA citizens/migrants following admission into the United States, which would also bear the admission stamp and notations that typically states “CFA/PAL” (Compact of Free Association/Palau), “CFA/FSM” (Compact of Free Association/ Federated States of Micronesia), or “CFA/MIS” (Compact of Free Association/Republic of Marshall Islands). Some older versions may be marked “CFA/RMI” for an RMI citizen. The admission period will indicate D/S (duration of status). Additionally, CFA citizens/migrants may be issued an electronic I-94, which the CFA citizen/migrant can access and print out a copy by visiting the CBP electronic I-94 printout website.

The United States Citizenship and Immigration Services (USCIS) may have also issued an I-766, Employment Authorization Document (EAD) with a category code of A08.

2. Anticipated SAVE Response

Based on information from the CFA citizen/migrant’s documentation, SAVE can provide an initial verification response of "Non-immigrant Employment Authorized – Indefinitely." The initial verification response may also include employment authorization information if the CFA citizen/migrant has a Form I-766, Employment Authorization Document.

If the claimant's immigration status could not be verified during the initial verification process, initiate the additional verification step. See GN 00303.620B.2 and GN 00303.630.

C. Field Office Processing Instructions for SSI Applications from CFA Citizens/Migrants Beginning September 26, 2026

NOTE: Before September 26, 2026, SSI applications from CFA citizens/migrants needed to be processed manually into force due (M02) payment status, following an Emergency Message (EM) that has since been archived. A Modernized Support System (MSS) Instruction provides guidance on how to convert those manually processed cases out of M02 payment status.

1. Field office actions when claimant is ineligible for reasons other than immigration status

If the claimant applies for SSI and is ineligible for reasons other than immigration status, deny the claim based on that other factor.

2. Field office actions when the CFA citizen/migrant is potentially eligible

Take the SSI application, review the immigration documents, and verify the claimant’s immigration status via SAVE. If the documentation verifies in SAVE, develop all other factors of eligibility, including sending the case to the Disability Determination Service (DDS) for a medical determination, if appropriate.

Follow normal policies to develop all other eligibility factors, including countable income, living arrangement, in-kind support and maintenance, and resources (e.g., SI 00810.007, SI 00830.105, SI 01110.210, SI 01140.010, SI 01140.100, and SI 00835.000).

REMINDER: Assess other benefit programs for which a claimant may be eligible based on their own activities or based on indirect qualification through family circumstances, e.g. consider the Marshall Islands social security program. See SI 00510.000.

To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0500502113

SI 00502.113 - SSI Eligibility for Compacts of Free Association (CFA) Citizens/Migrants - 09/25/2026
Batch run: 09/25/2026
Rev:09/25/2026

Social Security

Program Operations Manual System (POMS)