Policy/Memo 152

Number: Policy Memo 152
Date Issued: September 16, 2026
Subject: Dependents added to NYSHIP coverage due to relocating to the United States

PURPOSE:

Determine if dependents who are entering the United States from another country may be added to New York State Health Insurance Program (NYSHIP) without a waiting period.

BACKGROUND:

In accordance with NYSHIP plan rules, requests to add a previously eligible dependent to coverage outside of the annual open enrollment period are subject to a late enrollment waiting period unless the dependent experiences a loss of other coverage and the request is made within 30 days of the loss of coverage. The Employee Benefits Division (EBD) periodically receives requests from enrollees seeking to add a previously eligible child or spouse who has newly relocated to the United States. In some cases, dependents are moving from countries which provide universal health care. While the dependent may not have previously been enrolled in a “health plan,” they are effectively losing eligibility for and access to their previous coverage.

In the past, NYSHIP has not provided specific guidance regarding the first date of eligibility for a dependent added to a NYSHIP family policy following their relocation to the United States. However, recent requests for coverage have required that EBD make a determination as to whether this is a valid qualifying event to waive the late enrollment waiting period.

EBD has determined that going forward, requests to add a dependent to a NYSHIP policy due to the dependent’s relocation to the United States should be processed without a late enrollment waiting period when proof of relocation to the United States is provided (see below), the request is made within 30 days of the event, and it is confirmed that the country where the dependent previously resided provides universal or nearly universal healthcare to their citizens. In such cases, the late enrollment waiting period will be waived, and the dependent will be considered eligible as of the date they entered the United States. In cases in which the dependent is relocating from a country in which universal health care is not offered, and the dependent has not terminated their other coverage, a late enrollment waiting period will apply since the dependent has not experienced a loss of other coverage as a direct result of their relocation to the U.S.

In accordance with United States Citizenship and Immigration Services (USCIS) guidelines, the following documentation may be provided to verify the date of relocation to the United States:

• Form N-550 Certificate of Naturalization
• Form N-570 Certificate of Naturalization
• Form N-560 Certificate of Citizenship
• Form N-561 Certificate of Citizenship
• Form I-551 Permanent Resident Card (Green Card)
• Temporary I-551 Machine Readable Immigrant Visa (MRIV)
• Temporary I-551 Permanent Resident Stamp
• Form I-327 Permit to Re-Enter
• Form I-571 Refugee Travel Document
• Form I-766 Employment Authorization Document
• Form I-94 U.S. Customs and Border Protection (CBP) Arrival/Departure form

POLICY:

The late enrollment waiting period will be waived when a NYSHIP enrollee makes a timely request to add a dependent who has relocated to the United States from another country, required proof as outlined in this memo is provided, and EBD can verify that the country where the dependent previously resided provides universal or nearly universal health care. All requests pursuant to this policy should be submitted to EBD for consideration.

If proper proof of entry into the country cannot be provided, the request is not made in a timely manner, or EBD cannot verify that the country the dependent has relocated from offers universal healthcare, a late enrollment waiting period will be applied before the dependent’s coverage will go into effect.