The 2024 Survey of Medicaid and CHIP Eligibility, Enrollment, and Renewal Policies conducted by the Kaiser Family Foundation and Georgetown CCF highlights gains in maternal health coverage. Eleven states expanded coverage for pregnant people in the past year as detailed in the table below.
Nevada, North Dakota, and Tennessee, increased income eligibility limits for pregnant women closer to the national median of 200% for Medicaid and 258% for CHIP. Other states opened coverage pathways to more immigrant pregnant people. Georgia, Nevada, New Hampshire, North Dakota, and Rhode Island adopted the federal option to cover lawfully residing immigrants, commonly known as the “ICHIA” state option. Federal law does not generally allow federal matching funds to support Medicaid or CHIP for lawfully residing immigrants during their first five years in the U.S. Under the Children’s Health Insurance Program Reauthorization Act (CHIPRA), passed in 2009, states gained the option to access federal matching funds to cover children and/or pregnant women, effectively removing the five-year coverage bar for these groups. This option is known in the health policy world as the Immigrant Children’s Health Improvement Act (ICHIA) option. With the additional four, 30 states and Washington D.C. now provide Medicaid or CHIP coverage during pregnant women’s first five years in the U.S.
Alabama and Maryland moved to ensure prenatal care for all pregnant immigrants, regardless of status. CHIP’s From Coverage to End of Pregnancy (FCEP) option allows states to access federal CHIP match to cover undocumented pregnant people to promote health of the newborns, with the understanding that they will be born U.S. citizens. With the two new states, 22 states now cover pregnant people under FCEP.
FCEP coverage gets tricky when it comes to the new state option under ARPA to extend postpartum overage to 12 months—now taken up by all but two states. The statutory authority is challenging because the coverage is technically considered to be for the “unborn child.” For that reason, CMS guidance on the state postpartum coverage option made clear that the extended 12 months of coverage is not available to pregnant women covered under FCEP. Naturally the question among many states became: how do we fund up to 12 months of coverage for all pregnant women?
Alabama and Maryland offer coverage through the adoption of the CHIP FCEP option, formerly called unborn child option, for 60 days and 4 months respectively. Oregon, Vermont, and Maine provide 12-month postpartum coverage to people not otherwise eligible using state funds. Twenty-two states and Washington D.C. have extended coverage to immigrant women regardless of their immigration status through the CHIP FCEP option.
CMS’s guidance noted that states could use CHIP The Children’s Health Insurance Program’s (CHIP) Health Services Initiative (HSI) funds to extended postpartum coverage to FBEC pregnant women. CHIP The Children’s Health Insurance Program’s (CHIP) HhssHSI provides states with the opportunity to leverage higher CHIP federal match funds for interventions that impact children in low-income households.
More specifically, 11 states now provide postpartum coverage to immigrant women in the CHIP FCEP category.
