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Page 14 – FAQs

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public regarding existing requirements under the law. Frequently Asked Questions (FAQs) Sections 9812 and 9822 of the American Rescue Plan Act of 2021 (ARP): 12 Months Postpartum Coverage in Medicaid and the Children’s Health Insurance Program (CHIP) DECEMBER 14, 2021

The following questions and answers apply to implementation of the 12-month extended postpartum coverage option under sections 1902(e)(16) and 2107(e)(1)(J) of the Act as outlined in State Health Official (SHO) letter #21-007, “Improving Maternal Health and Extending Postpartum Coverage in Medicaid and the Children’s Health Insurance Program (CHIP).” General Requirements

Q1. Are states required to provide 12 months postpartum coverage for Medicaid and CHIP beneficiaries?

A1. No. States are not required to extend postpartum coverage in Medicaid and CHIP, but extending postpartum coverage offers opportunities to provide care that can reduce pregnancy- related death and severe maternal morbidity and improve continuity of care for chronic conditions including behavioral health conditions. States that have already expanded Medicaid eligibility to the adult group under 42 C.F.R. § 435.119, which has allowed more individuals to remain enrolled beyond the end of the month in which their 60th day postpartum occurs, report an increase in postpartum care visits, continuity in coverage, and enhanced engagement of individuals in health care.1

Q2. Are states able to extend postpartum coverage only under Medicaid or a separate CHIP?

A2. No. States that elect to extend postpartum coverage in Medicaid must also take up the option to extend postpartum coverage in their separate CHIP if they provide coverage to targeted low-income children (defined in section 2110(b) of the Act) who are pregnant and targeted low- income pregnant individuals (defined in section 2112 of the Act) in a separate CHIP. States may not adopt the option in a separate CHIP if the state does not elect to extend postpartum coverage in Medicaid.

Q3. Who is eligible for extended postpartum coverage on the effective date selected by the state?

A3. States that adopt the extended postpartum coverage option must provide 12 months of extended postpartum coverage to individuals who apply for coverage or become pregnant while enrolled in Medicaid or CHIP on or after the effective date of the state plan amendment (SPA). This includes individuals who apply for Medicaid after their pregnancy ends, but who were pregnant and received Medicaid-covered services in the state while pregnant on or after the effective date of the SPA if such services were received during a period of retroactive eligibility granted under section 1902(a)(34) of the Act and 42 C.F.R. § 435.915(a). In addition, states adopting this option must provide extended postpartum coverage to beneficiaries who are

1 Gordon, S.H., B.D. Sommers, I. Wilson, O. Galarraga, and A.N. Trivedi. “The Impact of Medicaid Expansion on Continuous Enrollment: A Two-State Analysis.” Journal of General Internal Medicine, vol. 34, no. 9, 2019, pp. 1919–1924.