It seems that every week brings a new development in the movement to extend postpartum coverage for 12 months, and this week was no different. On Wednesday, CMS added a “frequently asked questions” section to the extended postpartum coverage option guidance issued on December 7 (see page 14). The agency also released state-specific data on estimates of the number of pregnancies covered by Medicaid, occurrences of severe maternal morbidity among Medicaid beneficiaries and other maternal and infant health data through its T-MSIS data system.
The postpartum guidance FAQs affirm the details discussed in this guidance, which we blogged on last week. It also adds clarity on several important points on redeterminations and renewals, federal matching rates, and continuous eligibility protections.
First off, the FAQs make clear that for almost any pregnant individual, the end of their 12-month postpartum period will occur after the individual’s regular Medicaid or CHIP renewal date. This means that states who elect the extended postpartum coverage option will not need to conduct a renewal or redetermination of eligibility for the postpartum person until after their 12-month postpartum continuous eligibility period ends.
States also must provide 12 months of extended postpartum coverage through the same eligibility category the pregnant person was enrolled in during pregnancy, unless the state can determine that the postpartum person is eligible for another group conferring the same level of Medicaid coverage and benefits, without requesting any information from the beneficiary.
There are some exceptions. If states choose to, they can move a postpartum person to another eligibility group as long as the transition does not result in a reduction in coverage, and does not require additional information from the beneficiary. However, there are limitations on how much information states can use.
For one, states may not send a renewal form or request additional information from the individual in order to complete a redetermination or renewal based on changes in circumstance, unless the state has information indicating that the individual is no longer a state resident or has died. States also may not request additional information or terminate coverage for someone whose eligibility is renewed during the postpartum period, but who responds to the agency’s renewal notice that the information used to determine eligibility was not correct.
Finally, the FAQs got into even more detail on how extended postpartum coverage interacts with Medicaid expansion. For example, if an adult enrolled in the Medicaid expansion category becomes pregnant, they must be given the option to move to the pregnancy eligibility category and states must inform them of any difference in coverage between the two categories. If an individual enrolled in expansion does not elect to switch groups and remains in the expansion group during pregnancy and postpartum coverage, the state may still claim the enhanced FMAP for the individual through their redetermination at the end of the 12-month postpartum period.
As outlined in the original guidance, the FAQs confirm that states can work with CMS to adopt a proxy methodology to determine the percentage of postpartum people who would have otherwise been eligible to transition to the Medicaid expansion group after 60 days postpartum, and receive the enhanced expansion FMAP rate for those people.
CMS will also develop template Medicaid and CHIP state plan amendments to help streamline the application and approval process for state agencies and CMS, respectively. In all, it’s clear that encouraging states to extend postpartum coverage for 12 months after the end of pregnancy is a major priority for CMS heading into 2022 and beyond. We applaud their work to expand coverage during this critical time for maternal and infant health and development.