When a NH does not have enough U.S. coverage to meet fully insured status, but the
                  NH has at least six QCs, Field Office (FO) technicians must take an initial claim
                  to process the insured status denial. The initial denial automatically generates a
                  notice to inform the applicant that the applicant does not meet the insured status
                  requirement based on U.S. coverage alone. It also informs them that we will request
                  the applicant’s Italian earnings record.
               
               For more information about processing Totalization insured status notices for claims
                  for U.S. benefits, see GN 01702.315 through GN 01702.325.