Page 19

Page 19 – 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. order to enroll in Medicaid, the individual would need to establish eligibility on a basis other than their postpartum status.

Q16. In a separate CHIP, may states disenroll individuals for non-payment of premiums during their pregnancy or extended postpartum period?

A16. No. Section 2107(e)(1)(J) of the Act applies the requirements of section 1902(e)(16) of the Act to CHIP, which requires that an individual who was eligible under the state plan while pregnant remain eligible until the last day of the 12th month after the pregnancy ends, regardless of changes that may affect eligibility. Because the individual met all CHIP requirements during the pregnancy, they are entitled to continuous eligibility in CHIP for the entire duration of their pregnancy and extended postpartum period even if they do not pay premiums. Renewals for Individuals Receiving Extended Postpartum Coverage

Q17. When should states conduct renewals for pregnant and postpartum individuals?

A17. Pregnant individuals enrolled in Medicaid and CHIP in a state that elects to provide 12- months postpartum coverage are entitled to continued coverage through the end of the 12-month extended postpartum period regardless of changes in circumstances, except in the case of a change in state residency, voluntary termination, an erroneous determination of eligibility, or death. For almost all pregnant individuals, the end of the postpartum period will occur after the individual’s regular renewal date. States that adopt the 12-month extended postpartum option will not need to conduct a redetermination or renewal prior to the end of the extended postpartum period. The state will need to complete a full renewal, consistent with 42 C.F.R. § 435.916 and § 457.343, at the end of the extended postpartum period.

For example, Sydney applies for Medicaid in June 2022 and is enrolled in the eligibility group for pregnant individuals under 42 C.F.R. § 435.116 in a state that elects to provide 12-months postpartum coverage under section 1902(e)(16) of the Social Security Act. Sydney’s 12-month eligibility period for purposes of regular renewals, described at 42 C.F.R. § 435.916(a)(1), extends from June 1, 2022, to May 31, 2023. But because Sydney is eligible and enrolled in Medicaid while pregnant, she is entitled to continuous eligibility through the end of the month in which her 12-month postpartum period ends. Sydney’s pregnancy ends December 15, 2022. Her 12-month postpartum period ends December 31, 2023, which is after the end of her regular 12-month eligibility period (May 31, 2023). Because Sydney is eligible for continuous eligibility through the end of the extended 12-month postpartum period, the agency does not need to complete a renewal by May 31, 2023, and may not act on changes in circumstances until she reaches the end of her postpartum period (December 31, 2023).

Q18. Are states required to move pregnant and postpartum individuals between Medicaid eligibility groups during a period of continuous eligibility? What if the individual is enrolled in the adult group under 42 C.F.R. § 435.119 and becomes pregnant?

A18. No. A redetermination of eligibility is required to move individuals between eligibility groups, but because pregnant individuals are entitled to continuous eligibility, states electing to provide 12 months of extended postpartum coverage do not need to complete a renewal or act on