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Date 12-month Medicaid postpartum coverage from each state's approval - #10241

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@hua7450 hua7450 commented Oct 15, 2026 •

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Fixes #10464

Summary

postpartum_coverage.yaml set 365 days for Illinois, Louisiana, Michigan, New Jersey and Virginia from 2021-01-01 and 60 days for the other 46 jurisdictions. It had not been updated since it was added. 42 USC 1396a(e)(16) (ARPA §9812, made permanent by CAA 2023 §5113) lets a state cover pregnant people through the month in which a 12-month postpartum period ends. Fifty jurisdictions now do so through a state plan amendment (SPA) or a section 1115 demonstration. Arkansas is the only exception.

This PR dates each state's 365-day value from the date its extension took effect. For most states that is the effective date in the CMS approval. Florida and Virginia received approvals that deferred coverage, so their dates follow the start of coverage. The PR also moves the five existing 365-day states to those dates. The parameter has a single statutory reference covering sections 1396a(e)(5) and (16), linked at (e)(16).

Example (is_pregnant_for_medicaid, 2025): a Texas mother between 60 days and 12 months postpartum, earning $20,000 and living with an infant. On main the result is false; with this PR it is true (SPA TX-23-0028, effective 2024-03-01).

Effective dates

Effective dates follow the CMS state plan and section 1115 demonstration approvals cited below. Page numbers are PDF file pages.

All 51 jurisdictions
State main This PR Authority (approval letter page)
Alabama 60 365 from 2022-10-01 Alabama State Plan Amendment AL-22-0007 (p. 1)
Alaska 60 365 from 2024-02-01 Alaska State Plan Amendment AK-24-0001 (p. 2)
Arizona 60 365 from 2023-04-01 Arizona State Plan Amendment AZ-22-0009 (p. 2)
Arkansas 60 60 (not adopted) —
California 60 365 from 2022-04-01 California State Plan Amendment CA-22-0030 (p. 2)
Colorado 60 365 from 2022-07-01 Colorado State Plan Amendment CO-22-0009 (p. 2)
Connecticut 60 365 from 2022-04-01 Connecticut State Plan Amendment CT-22-0016 (p. 2)
Delaware 60 365 from 2022-07-01 Delaware State Plan Amendment DE-22-0011 (p. 2)
District of Columbia 60 365 from 2022-04-01 District of Columbia State Plan Amendment DC-22-0001 (p. 2)
Florida 60 365 from 2022-07-01 Florida Managed Medical Assistance section 1115 demonstration amendment (p. 1-2); Florida Senate Bill 2526 (2022), enrolled, sections 6 and 11 (p. 11-12, 21)
Georgia 60 365 from 2022-11-01 Georgia State Plan Amendment GA-22-0005 (p. 2)
Hawaii 60 365 from 2022-04-01 Hawaii State Plan Amendment HI-22-0008 (p. 2)
Idaho 60 365 from 2025-01-01 Idaho State Plan Amendment ID-25-0001 (p. 2)
Illinois 365 from 2021-01-01 365 from 2021-04-12 Illinois Continuity of Care and Administrative Simplification section 1115 demonstration amendment (p. 1); Illinois State Plan Amendment IL-22-0020 (p. 2)
Indiana 60 365 from 2022-04-01 Indiana State Plan Amendment IN-22-0001 (p. 2)
Iowa 60 365 from 2025-04-01 Iowa State Plan Amendment IA-25-0018; Iowa State Plan Amendment IA-25-0019
Kansas 60 365 from 2022-04-01 Kansas State Plan Amendment KS-22-0015 (p. 2); Kansas State Plan Amendment KS-22-0016 (p. 2)
Kentucky 60 365 from 2022-04-01 Kentucky State Plan Amendment KY-22-0002 (p. 2)
Louisiana 365 from 2021-01-01 365 from 2022-04-01 Louisiana State Plan Amendment LA-22-0009 (p. 3)
Maine 60 365 from 2022-08-01 Maine State Plan Amendment ME-22-0016 (p. 2)
Maryland 60 365 from 2022-04-01 Maryland State Plan Amendment MD-22-0014 (p. 2)
Massachusetts 60 365 from 2022-04-01 Massachusetts State Plan Amendment MA-22-0014 (p. 2)
Michigan 365 from 2021-01-01 365 from 2022-04-01 Michigan State Plan Amendment MI-22-0100 (p. 3)
Minnesota 60 365 from 2022-07-01 Minnesota State Plan Amendment MN-22-0008 (p. 2)
Mississippi 60 365 from 2023-04-01 Mississippi State Plan Amendment MS-23-0015 (p. 2)
Missouri 60 365 from 2023-07-07 Missouri State Plan Amendment MO-23-0022 (p. 2)
Montana 60 365 from 2023-07-01 Montana State Plan Amendment MT-23-0018 (p. 2)
Nebraska 60 365 from 2024-01-01 Nebraska State Plan Amendment NE-24-0003 (p. 2)
Nevada 60 365 from 2024-01-01 Nevada State Plan Amendment NV-23-0033 (p. 2)
New Hampshire 60 365 from 2023-10-01 New Hampshire State Plan Amendment NH-23-0005 (p. 2)
New Jersey 365 from 2021-01-01 365 from 2021-10-28 New Jersey FamilyCare Comprehensive Demonstration section 1115 amendment (p. 1); temporary extensions of June 2022, November 2022 and January 2023 (p. 1); 2023-2028 extension approval, expenditure authority 6 (p. 27)
New Mexico 60 365 from 2022-04-01 New Mexico State Plan Amendment NM-22-0013 (p. 2)
New York 60 365 from 2023-03-01 New York State Plan Amendment NY-23-0006 (p. 2)
North Carolina 60 365 from 2022-04-01 North Carolina State Plan Amendment NC-22-0012 (p. 2)
North Dakota 60 365 from 2023-01-01 North Dakota State Plan Amendment ND-22-0025 (p. 1)
Ohio 60 365 from 2022-04-01 Ohio State Plan Amendment OH-22-0018 (p. 2)
Oklahoma 60 365 from 2023-01-01 Oklahoma State Plan Amendment OK-22-0042 (p. 2)
Oregon 60 365 from 2022-04-01 Oregon State Plan Amendment OR-22-0008 (p. 2)
Pennsylvania 60 365 from 2022-04-01 Pennsylvania State Plan Amendment PA-22-0016 (p. 2)
Rhode Island 60 365 from 2022-10-01 Rhode Island State Plan Amendment RI-22-0024 (p. 2)
South Carolina 60 365 from 2022-04-22 South Carolina State Plan Amendment SC-22-0004 (p. 3)
South Dakota 60 365 from 2023-07-01 South Dakota State Plan Amendment SD-23-0008 (p. 3)
Tennessee 60 365 from 2022-04-01 TennCare notice of change, maternal health enhancements (p. 1); Tennessee CHIP State Plan Amendment TN-22-0021 (p. 2)
Texas 60 365 from 2024-03-01 Texas State Plan Amendment TX-23-0028 (p. 2)
Utah 60 365 from 2024-01-01 Utah State Plan Amendment UT-23-0017 (p. 2); from 2026-01-01 Utah State Plan Amendment UT-25-0024 (p. 2) and Utah Medicaid Reform section 1115 demonstration amendment (p. 3, 26, 90)
Vermont 60 365 from 2023-04-01 Vermont State Plan Amendment VT-23-0004 (p. 2)
Virginia 365 from 2021-01-01 365 from 2022-07-01 Virginia FAMIS MOMS and FAMIS Select section 1115 demonstration amendment (p. 1, 10); semi-annual monitoring report, July to December 2023 (p. 12)
Washington 60 365 from 2022-04-01 Washington State Plan Amendment WA-22-0012 (p. 2)
West Virginia 60 365 from 2022-04-01 West Virginia State Plan Amendment WV-22-0007 (p. 2)
Wisconsin 60 365 from 2026-06-01 Wisconsin State Plan Amendment WI-26-0014 (p. 2)
Wyoming 60 365 from 2023-07-01 Wyoming State Plan Amendment WY-23-0005 (p. 2)

Source notes

  • District of Columbia and Delaware. KFF's tracker links DC to Delaware's SPA DE-22-0011 and Delaware to a 2021 bill. DC's own SPA is DC-22-0001, effective 2022-04-01. DE-22-0011 elects the option for Delaware from 2022-07-01.
  • Florida. CMS approved the 1115 amendment on 2022-05-25, but the letter delays the extension until Florida SB 2526 takes effect (pages 1-2). SB 2526 section 6 adds s. 409.814(4), which keeps Title XXI (Kidcare) coverage through the 12-month postpartum period for enrollees who turn 19 (pages 11-12). CMS required this CHIP change before the Medicaid extension could start. Section 11 makes the act effective 2022-07-01 (page 21). The Medicaid 12-month rule is in s. 409.903(5), as amended by ch. 2021-41 (SB 2518, 2021).
  • Virginia. CMS approved the 1115 amendment effective 2021-11-18 (page 1). The special terms start the extension "following the effective date of these STCs and an operational ramp-up period" (page 10). DMAS reported to CMS that it implemented extended postpartum coverage effective July 1, 2022 (monitoring report page 12), and the DMAS provider FAQ gives the same date.
  • Tennessee. TennCare covers its Medicaid population under the TennCare III 1115 demonstration. TennCare's notice gives 2022-04-01, as does CMS's approval of companion CHIP SPA TN-22-0021, which calls itself "a companion to the Medicaid continuous postpartum coverage in Tennessee's 1115 waiver." I did not find a separate CMS letter for the Medicaid side.
  • Illinois. The 1115 amendment took effect 2021-04-12. SPA IL-22-0020 moved the coverage to the state plan from 2022-07-01, so the value does not change.
  • New Jersey. The 1115 amendment took effect 2021-10-28, and the approval runs through 2022-06-30. CMS temporary extensions (June 2022, November 2022 and January 2023) kept the 2021 special terms in force through March 31, 2023. The March 30, 2023 extension approval continues the 12-month postpartum extension from April 1, 2023 through June 30, 2028 (expenditure authority 6, page 27). I found no New Jersey SPA that elects the option. DMAHS reported that it built the system change during 2022 (MAAC, January 27 and July 12, 2022; February 1, 2023), while FFCRA continuous enrollment kept postpartum members covered. The model uses the 2021-10-28 legal effective date, because the STCs do not defer the start and no go-live date is published.
  • Iowa. SPAs IA-25-0018 and IA-25-0019 superseded the original January 1, 2025 approval and moved the extension to April 1, 2025. Annual simulations therefore apply the 60-day rule in 2025 and the 12-month extension from 2026.
  • Kansas. The eligibility election is SPA KS-22-0015 (approved 2022-07-26, effective 2022-04-01). KS-22-0016, the SPA KFF links, makes the matching Alternative Benefit Plan change with the same effective date.
  • Wisconsin. SPA WI-26-0014 was approved on 2026-09-14, effective 2026-06-01. KFF and the Governor's release give July 1, 2026 as the go-live. The SPA date is the legal effective date, and both dates give 60 in annual 2026 and 365 in 2027.
  • Utah. SPA UT-25-0024 removed the state plan election from 2026-01-01 and moved the coverage into the Utah Medicaid Reform 1115 demonstration (amendment approved 2025-11-13). Under special term 4.3(i), anyone enrolled in Medicaid while pregnant keeps 12 months of continuous coverage, so the 365-day value does not change. That demonstration runs through 2027-06-30 unless extended.
  • New Jersey link. nj.gov has removed its copy of the approval PDF, so the link points to the medicaid.gov copy of the same approval document, whose first page is the CMS letter.
  • Shorter or limited-benefit extensions that preceded a state's 12-month election are not modeled, and neither is state-only coverage. count_days_postpartum cannot represent a 6-month period anyway: under_12_months_postpartum maps to 60 days.

Modeling notes

  • is_pregnant_for_medicaid_nfc is YEAR-defined, so annual simulations read the value in effect on January 1. A mid-year effective date applies from the next calendar year (Texas from 2025, Wisconsin from 2027). The NV pregnancy income-limit cases already follow this convention.
  • The 365-day value and the count_days_postpartum < limit comparison are unchanged. The statute runs coverage through the end of the month in which the 12-month period ends, so day 365 is usually still covered in law.

CHIP

There is no CHIP postpartum parameter, and none is needed. SHO 21-007 says a Medicaid election also applies to separate-CHIP "targeted low-income pregnant women" (pages 4 and 7). Postpartum coverage under the unborn-child (FCEP) option is limited, and states covering only unborn children in CHIP need not elect it (pages 2 and 7). CHIP should therefore read this Medicaid parameter for its targeted-low-income-pregnant pathway.

is_chip_eligible_standard_pregnant_person (CO, KY, MO, NJ, RI, VA, WV) tests is_pregnant only and applies no postpartum period at all, not even 60 days. is_chip_fcep_eligible_person also applies none, which is consistent with the unborn-child option. I left the CHIP gap for #10362 (PR #10363).

Out of scope

Merge order

Merge this PR before #10363, which reads is_pregnant_for_medicaid_nfc. #10365 also appends to is_pregnant_for_medicaid.yaml; whichever PR merges second keeps both blocks.

Tests

Seventeen cases were appended to is_pregnant_for_medicaid.yaml:

  • A Texas household (mother aged 28, $20,000 wages, infant, under_12_months_postpartum) in 2024 (mother not covered, category NONE; the election starts in March) and 2025 (mother covered as PREGNANT). The infant is INFANT in both years, and each person has their own marital unit.
  • The California 364/365-day boundary (2023), which pins the model's count_days_postpartum < 365 cutoff
  • Arkansas in 2026 at 59 days (covered) and 90 days (not covered)
  • Wisconsin at 90 days in 2026 (not covered) and 2027 (covered)
  • Iowa at 90 days in 2025 (not covered; the extension starts in April) and 2026 (covered)
  • Illinois and New Jersey at 90 days in 2021 (not covered; both 1115 dates fall after January 1) and 2022 (covered)
  • Louisiana, Michigan and Virginia at 90 days in 2022 (not covered; all three start after January 1) and 2023 (covered)
  • Idaho at 90 days in 2024 (not covered) and 2025 (covered; SPA ID-25-0001 takes effect January 1)
  • Utah at 90 days in 2024 (covered; SPA UT-23-0017 takes effect January 1) and 2026 (covered under the section 1115 demonstration)

New cases assert is_pregnant_for_medicaid_nfc beside is_pregnant_for_medicaid. The existing postpartum cases keep their expected values. These are California at 59 and 60 days in 2022, and the ICHIA cases for New Jersey and Illinois in 2025. No partner contract test (tests/policy/baseline/partners/**) sets a postpartum input. Tests were not run locally for the review-round changes; CI validates them. make format (ruff 0.15.5) passed on the round-2 head. The PR diff remains limited to the postpartum parameter, pregnancy tests, and changelog fragment.

Review changes (round 1)

  • Virginia now reads 365 from 2022-07-01, the date DMAS implemented the extension. Only annual 2022 changes: a Virginia woman at day 60 or later of the 12-month period gets the 60-day rule that year.
  • New Jersey cites the temporary extensions and the 2023-2028 renewal, so every year from 2022 has a supporting source. The values did not change.
  • The parameter description counts from the end of the pregnancy, the unit stays day, and a comment states the January 1 read and the day-365 cutoff.

Review changes (round 2)

  • Two cases pin Utah's 2024-01-01 start (90 days in 2024, covered) and Arkansas's 60-day period (59 days in 2026, covered).
  • A comment beside NJ: 2021-10-28: 365 records that the amendment has no deferred start and that DMAHS finished the system change during 2022. The value did not change.
  • The description now reads "States continue eligibility as though the individual were still pregnant for this number of days after a pregnancy ends", which fits both the 60-day period (42 USC 1396a(e)(5)) and the full-benefit 12-month period.
  • The Florida note now reads SB 2526 section 6 as the CHIP (Kidcare) change that CMS required.

axiom: TheAxiomFoundation/rulespec-us#1928 queued

🤖 Generated with Claude Code

hua7450 and others added 2 commits October 21, 2026 16:57
postpartum_coverage.yaml set 365 days for five states from 2021-01-01
and 60 days for the other 46 jurisdictions. Fifty jurisdictions (all but
Arkansas) now cover 12 months postpartum under 42 USC 1396a(e)(16) or a
section 1115 demonstration. Date each value from the CMS approval letter
(or, for Tennessee, TennCare's notice and its companion CHIP SPA; for
Florida, the SB 2526 effective date the 1115 approval requires), and add
YAML cases for the annual effective-date boundary.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
…ed link, per-person test entities

Add the UT-25-0024 SPA and the Utah Medicaid Reform 1115 amendment, which carry Utah's 12-month postpartum authority from 2026-01-01. Cite Kansas eligibility SPA KS-22-0015 next to ABP SPA KS-22-0016. Point the New Jersey 1115 approval at its Internet Archive copy, since nj.gov removed the file. Give each person in the three multi-household test cases their own tax unit, SPM unit, family and marital unit. No values or expected outputs change.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>

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Program Review

PR #10241, "Date 12-month Medicaid postpartum coverage from each state's approval" (hua7450). Round 1, full review.

IDs: C = critical, SA = should address, G = suggestion.

Paths: P = policyengine_us/parameters/gov/hhs/medicaid/eligibility/categories/pregnant/postpartum_coverage.yaml, T = policyengine_us/tests/policy/baseline/gov/hhs/medicaid/eligibility/categories/is_pregnant_for_medicaid.yaml. Line numbers refer to the reviewed head. Every PDF link uses the file page number, not the printed page number.

Source Documents

Branch Status

  • The branch is 5 commits ahead and 14 behind main (12b899c11a), and it is MERGEABLE. The staleness did not affect any finding.
  • Merge order: PR #10365 (same author) also edits is_pregnant_for_medicaid.yaml and appends cases after line 137. Whichever PR merges second must rebase and keep both blocks.

What is correct

The PR does what it says for 48 of the 50 electing jurisdictions. All 45 SPA states have the effective date from their CMS approval letter. Reviewers read each letter on the page image, and the second SPAs for IA, KS and UT, IL-22-0020 and CHIP SPA TN-22-0021 also match. Across all 50 SPA entries, no date is wrong, and no #page= anchor in the 58 reference entries is wrong. The hard cases are right. Iowa's 2025-04-01 follows the IA-25-0018 supersession. Florida's 2022-07-01 follows the letter's deferral to SB 2526. Tennessee is 2022-04-01. Utah's 365 continues across 2026-01-01 under its 1115. Wisconsin's 2026-06-01 is the SPA's legal date. DC's own SPA is DC-22-0001, and Arkansas stays at 60. Moving LA and MI to 2022-04-01 is right, because no SPA could take effect before that date (ARPA 9812(b)). Keeping 365 open-ended is right, because CAA 2023 5113 removed the 2027 sunset. All 10 new test cases are correct by hand check. CI and every local run pass.

Critical (Must Fix)

C1. Virginia's 12-month coverage starts on the 1115 approval date, but coverage began on 2022-07-01.

  • Where: P:258-260 (2021-11-18: 365), reference P:114-115.
  • Evidence: The approval is effective November 18, 2021 (#page=1). The STCs say that Virginia, "following the effective date of these STCs and an operational ramp-up period, will begin to implement the extension of postpartum coverage" (#page=10). DMAS's report to CMS says "effective July 1, 2022, DMAS implemented extended postpartum coverage" (#page=12). The DMAS provider FAQ and the VCU infographic also give July 1, 2022. No source gives an earlier start. All pages were read as images.
  • Why: The PR dates Florida from the start of coverage (SB 2526), not from its 2022-05-25 letter, so Virginia should follow the same rule. The repo also has the rule "add a dated entry at the implementation date" for an approved 1115 (parameters/gov/hhs/medicaid/eligibility/categories/parent/income_limit.yaml:213-217). The effect is confirmed on the code path. Annual 2022 reads 365 for VA. A VA postpartum person between 138% and 148% FPL is eligible in 2022 under the PR and not eligible under the law. Below 138%, the category changes from ADULT to PREGNANT. The years 2021 and 2023-2026 do not change.
  • Fix in P:
VA:
  2021-01-01: 60
  # CMS approved the section 1115 amendment on 2021-11-18. The STCs defer
  # coverage to an operational ramp-up period, and DMAS implemented the
  # 12-month extension on 2022-07-01.
  2022-07-01: 365

Replace the reference at P:114-115 with:

    - title: "CMS approval of the Virginia FAMIS MOMS and FAMIS Select section 1115 demonstration amendment #page 1,10"
      href: https://www.medicaid.gov/Medicaid-CHIP-Program-Information/By-Topics/Waivers/1115/downloads/va/va-famis-moms-famis-select-11182021-ca.pdf#page=1
    - title: Virginia FAMIS MOMS and FAMIS Select section 1115 demonstration semi-annual monitoring report, July to December 2023
      href: https://www.medicaid.gov/medicaid/section-1115-demonstrations/downloads/va-famis-moms-famis-select-semi-annl-rpt-07012023-12312023.pdf#page=12

Add the VA rows in SA2. In the PR body, change the Virginia row to "365 from 2022-07-01" and add a source note. In the changelog, change "on their approved dates" to "on the dates their extensions took effect".

C2. New Jersey's only reference expires on 2022-06-30, so no reference supports 365 from 2022-07-01, including 2026.

  • Where: reference P:76-77. The values at P:216-218 are correct and do not change.
  • Evidence: The cited 2021 amendment says "This approval is effective October 28, 2021 through June 30, 2022, upon which date, unless extended or otherwise amended, all authorities granted to operate this demonstration will expire" (#page=1). The PR body says that the renewal was not checked. The review found no gap. Three CMS temporary extensions keep the 2021 STCs in force: June 7, 2022 to 2022-12-31, November 28, 2022 to 2023-01-31, and January 26, 2023 to 2023-03-31. The March 30, 2023 approval then runs from April 1, 2023 to June 30, 2028 (#page=1). It contains expenditure authority 6.a, "Postpartum Extension ... to the end of the 12th month following the end of the pregnancy" (#page=27), and STC 5.15 (#page=77).
  • Fix: keep P:76-77 and insert after line 77. The last entry is required, because it covers 2026. The three temporary extensions are recommended, because annual 2023 reads 2023-01-01 and only the November 28, 2022 letter covers that date.
    - title: CMS temporary extension of the New Jersey FamilyCare Comprehensive Demonstration through December 31, 2022
      href: https://www.medicaid.gov/sites/default/files/2022-06/nj-1115-request-ca1.pdf#page=1
    - title: CMS temporary extension of the New Jersey FamilyCare Comprehensive Demonstration through January 31, 2023
      href: https://www.medicaid.gov/sites/default/files/2023-01/nj-1115-request-ca2.pdf#page=1
    - title: CMS temporary extension of the New Jersey FamilyCare Comprehensive Demonstration through March 31, 2023
      href: https://www.medicaid.gov/sites/default/files/2023-01/nj-1115-request-ca3.pdf#page=1
    - title: CMS approval of the New Jersey FamilyCare Comprehensive Demonstration section 1115 extension, expenditure authority 6 (postpartum extension)
      href: https://www.medicaid.gov/medicaid/section-1115-demonstrations/downloads/nj-1115-cms-exten-demnstr-aprvl-03302023.pdf#page=27

In the PR body (line 80), replace "I did not check the later demonstration renewal" with: "CMS temporary extensions (June 7, 2022; November 28, 2022; January 26, 2023) kept the 2021 STCs in force through March 31, 2023, and the March 30, 2023 extension approval continues the 12-month postpartum extension from April 1, 2023 through June 30, 2028 (expenditure authority 6, STC 5.15)." Add the 2023 approval to the New Jersey row of the table.

Should Address

SA1. The CA boundary test says that SPA CA-22-0030 stops coverage at day 365, but the SPA says the opposite.

  • Where: T:187-188.
  • Evidence: The CA-22-0030 S-page covers the person "through the last day of the month in which a 12-month postpartum period (beginning on the last day of the pregnancy) ends" (#page=8, read as an image). Day 365 is still covered for about 97.5% of pregnancy-end dates. The day-365 cutoff comes from the model's strict count_days_postpartum < postpartum_coverage comparison. Your PR body (line 91) and the file header (T:139-140) say the same thing. The repo already names this convention correctly in is_medicaid_lawfully_residing_option_eligible.yaml:162-166.
  • Fix: replace T:187-188 with the lines below. Do not change the inputs or the expected [true, false]. This version was run and passes.
# This pins the model's postpartum day limit (count_days_postpartum <
# postpartum_coverage). SPA CA-22-0030 and 42 USC 1396a(e)(16)(A) run coverage
# through the last day of the month in which the 12-month postpartum period
# ends, so day 365 is usually still covered in law.
- name: CA postpartum coverage holds at 364 days and stops at the model's 365-day postpartum limit

Do not move the person to day 396. Under one reading of the 12-month period, day 396 can still be covered, and the move removes the only test of the 365 boundary.

SA2. Two of the five moved start dates (LA, MI) have no test, and VA needs one after C1.

  • Where: P:177-179 (LA), P:189-191 (MI), P:258-260 (VA). No test sets a postpartum input for these states.
  • Evidence: Before the PR, LA and MI read 365 from 2021-01-01. Now annual 2021 and 2022 read 60, and 365 applies from annual 2023 (LA-22-0009 #page=3, MI-22-0100 #page=3). The changelog names all five moves, but only IL and NJ have tests (T:286-364).
  • Fix: append the two cases below to T. The expected values assume the C1 fix. These cases were run at the head: LA and MI pass as written, and VA gives true in 2022 until C1 is applied. A probe with VA at 2022-07-01 gives false in 2022 and true in 2023.
# Louisiana (SPA LA-22-0009) and Michigan (SPA MI-22-0100) elect the option
# from 2022-04-01, and Virginia's section 1115 coverage began 2022-07-01. All
# three start after January 1, 2022, so annual 2022 applies the 60-day rule
# and annual 2023 applies 12 months.
- name: LA, MI and VA postpartum extensions do not apply in annual 2022
  period: 2022
  input:
    people:
      person1:
        count_days_postpartum: 90
        medicaid_income_level: 1
      person2:
        count_days_postpartum: 90
        medicaid_income_level: 1
      person3:
        count_days_postpartum: 90
        medicaid_income_level: 1
    tax_units:
      tax_unit1:
        members: [person1]
      tax_unit2:
        members: [person2]
      tax_unit3:
        members: [person3]
    spm_units:
      spm_unit1:
        members: [person1]
      spm_unit2:
        members: [person2]
      spm_unit3:
        members: [person3]
    families:
      family1:
        members: [person1]
      family2:
        members: [person2]
      family3:
        members: [person3]
    marital_units:
      marital_unit1:
        members: [person1]
      marital_unit2:
        members: [person2]
      marital_unit3:
        members: [person3]
    households:
      household1:
        members: [person1]
        state_code: LA
      household2:
        members: [person2]
        state_code: MI
      household3:
        members: [person3]
        state_code: VA
  output:
    is_pregnant_for_medicaid_nfc: [false, false, false]
    is_pregnant_for_medicaid: [false, false, false]

For the second case, copy the first case. Set name: LA, MI and VA postpartum extensions apply in 2023 and period: 2023, and set both outputs to [true, true, true].

Suggestions

G1. The statute reference opens at (e)(5), but 50 of the 51 values rest on (e)(16). P:8-9. The title cites "(e)(5) and (16)", and the href opens #e_5. The #e_16 anchor is about 6,200 words further down the same page. The citation itself is correct. Fix: keep one entry, because CLAUDE.md:151 asks for one entry per source document. Point it at the provision that this PR implements:

    - title: 42 U.S. Code § 1396a(e)(5) and (16)
      href: https://www.law.cornell.edu/uscode/text/42/1396a#e_16

If you read the two anchors as separate sources, you can restore the two entries from commit 11935ca609 (#e_5 and #e_16) instead.

G2. The TX cases put the infant in the mother's marital unit. T:155-161 and T:176-182. Only tax_units and households are given, so the default marital unit holds the mother and the infant. CLAUDE.md:215-219 says that marital units do not include children, and the Medicaid non-filer helpers read nb_persons() == 2 as married. The outputs do not change today. Fix: in both cases, add these units between tax_units and households. Both cases were run and pass with unchanged outputs.

    spm_units:
      spm_unit:
        members: [person1, person2]
    families:
      family:
        members: [person1, person2]
    marital_units:
      marital_unit1:
        members: [person1]
      marital_unit2:
        members: [person2]

G3. State the two modeling conventions once in P. The January 1 read and the day-365 cutoff are explained only in test comments and the PR body. As a result, a later editor can "correct" the dates or the 365 value by mistake. Fix: add this comment between description: and metadata::

# NOTE: is_pregnant_for_medicaid_nfc is YEAR-defined and reads this parameter
# on January 1, so a mid-year effective date applies from the next calendar
# year. 60 and 365 are the statutory minimum day counts: 42 USC 1396a(e)(5)
# and (e)(16) run coverage through the last day of the month in which the
# 60-day or 12-month period ends, but count_days_postpartum has no calendar
# date, so the model stops coverage at day 60 or day 365.

G4. The description counts from birth and describes the model, not the law. This is the pre-existing line P:1, in the block that the PR edits. The statute counts from "the last day of her pregnancy" (any pregnancy outcome). The label P:4 also does not name the quantity. Fix:

description: States provide pregnancy-related coverage for this number of days after a pregnancy ends under the Medicaid program.
metadata:
  unit: day
  label: Medicaid postpartum coverage period

G5. Six new cases assert only the combined output. T:226, T:235, T:246, T:255, T:324, T:364. is_pregnant_for_medicaid_fc is true in each case today, so the tests work. But a later change to an income limit could make a false pass for the wrong reason. Fix: add the postpartum output beside the combined one, as the TX and IA cases do. Use is_pregnant_for_medicaid_nfc: [true, false] at 226, false at 235 and 246, true at 255, [false, false] at 324 and [true, true] at 364. Optional: only the IA cases set age: 28, so use one pattern for all cases.

G6. Test the same-year side of the January 1 read, Utah's 2026 transition, and Arkansas inside 60 days. Every tested start date is mid-year. Utah is the only state whose legal authority changes in 2026, and Arkansas is tested only at 90 days. Fix: append these cases. They were run at the head, and all pass.

# SPA ID-25-0001 takes effect on January 1, 2025, so annual 2025 applies
# 12 months in the same year.
- name: ID postpartum coverage stays at 60 days in 2024
  period: 2024
  input:
    state_code: ID
    count_days_postpartum: 90
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: false
    is_pregnant_for_medicaid: false

- name: ID postpartum coverage extends to 12 months in 2025 under SPA ID-25-0001
  period: 2025
  input:
    state_code: ID
    count_days_postpartum: 90
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: true
    is_pregnant_for_medicaid: true

# SPA UT-25-0024 moved Utah's election into the Medicaid Reform section 1115
# demonstration on 2026-01-01, and 12-month coverage continues.
- name: UT postpartum coverage stays at 12 months in 2026 under the section 1115 demonstration
  period: 2026
  input:
    state_code: UT
    count_days_postpartum: 90
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: true
    is_pregnant_for_medicaid: true

- name: AR postpartum coverage holds inside the 60-day period in 2026
  period: 2026
  input:
    state_code: AR
    count_days_postpartum: 59
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: true
    is_pregnant_for_medicaid: true

- name: AR mother between 60 days and 12 months postpartum is not covered as pregnant in 2026
  period: 2026
  input:
    state_code: AR
    age: 28
    under_12_months_postpartum: true
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: false
    is_pregnant_for_medicaid: false

G7. Show the household gain in the TX cases. T:162-164 and T:183-185. Only is_pregnant_for_medicaid is asserted. The example in the PR body is a Medicaid eligibility gain. Fix: add these outputs. They were run with the G2 entities and pass.

    # TX 2024 case
    medicaid_category: [NONE, INFANT]
    is_medicaid_eligible: [false, true]
    # TX 2025 case
    medicaid_category: [PREGNANT, INFANT]
    is_medicaid_eligible: [true, true]

Optional: a 2027 medicaid_work_requirement_eligible pair (an electing expansion state against AR) would pin the postpartum exemption. Run it before you add it, and leave the infant out of the tax unit.

G8. Explain why the CA 2022 cases still apply 60 days. T:28-42 (outside the diff). After this PR, CA is 365 from 2022-04-01, and these cases pass only because of the January 1 read. Fix: add this comment above line 28:

# California elected 12 months from 2022-04-01 (SPA CA-22-0030). The annual
# variable reads January 1, so annual 2022 still applies the 60-day rule.

G9. Use the official copy of the New Jersey 2021 letter. P:77. The Wayback link opens an HTML wrapper, so #page= does not reach the PDF. medicaid.gov hosts the same 483-page file, with the letter on file page 1. Fix:

      href: https://www.medicaid.gov/Medicaid-CHIP-Program-Information/By-Topics/Waivers/1115/downloads/nj/nj-1115-request-ca.pdf#page=1

Update the "New Jersey link" note in the PR body (line 85).

G10. Two optional source pages: Florida SB 2526 section 6 and Utah 1115 page 90. P:28 and P:110. Section 11 of SB 2526 (#page=21) gives only the act's effective date. The substantive 12-month change is section 6 (s. 409.814, file pages 11-12). Utah 1115 file page 90 (Table 8) is the only page that prints the 1/1/2026 start of the extended postpartum group. Fix:

    - title: "Florida Senate Bill 2526 (2022), enrolled, sections 6 and 11 #page 11-12,21"
      href: https://www.flsenate.gov/Session/Bill/2022/2526/BillText/er/PDF#page=11
    - title: "CMS approval of the Utah Medicaid Reform section 1115 demonstration amendment #page 3,26,90"
      href: https://www.medicaid.gov/medicaid/section-1115-demonstrations/downloads/ut-medicaid-reform-appvl-11132025.pdf#page=3

G11. Record the Wisconsin date conflict in the PR body. The Wisconsin note (body line 83) gives only the SPA dates. KFF and the Governor's release say that coverage went into effect on July 1, 2026. Fix: add "KFF and the Governor's release give July 1, 2026 as the go-live. The SPA's legal effective date is June 1, 2026, and both dates give 60 in annual 2026 and 365 in 2027." This prevents a later "correction" to July 1.

Investigated and cleared

  • Illinois 2021-04-12. The 1115 STCs have no ramp-up clause (STC 16, #page=12). The Governor announced the coverage the next day. The HFS monitoring report counts the population from April 2021 (#page=6). No one entered the demonstration group, because the PHE continuous-enrollment rule already covered these women (#page=2). That is a second basis of coverage, not a later start. The date is right. You can cite the report beside the letter if you want.
  • Page lists in the Utah (P:110) and Florida (P:26) titles. Both follow CLAUDE.md:151-155: one entry per document, the href opens the first page, the title ends with the quoted page list. Splitting them would break line 151. No change.
  • Utah across 2026-01-01. UT-25-0024 (#page=2) moves the election into the 1115. The 1115 starts coverage on the SPA date (#page=3) with the same 12-month rule (STC 4.3(i), #page=26). There is no gap, and no 2026 entry is needed. UT-23-0017 is effective 2024-01-01 (#page=2).
  • MO-23-0022 and IA-25-0019 copies. The SHA-256 hashes and byte sizes match the live medicaid.gov files.
  • Wisconsin June 1 against July 1. The SPA date is the legal date. The release's "pregnant or still within 60 days postpartum as of May 31, 2026" agrees with June 1. There is no annual output effect.
  • Severity disputes settled by the verifiers. The statute anchor and the TX entities are SUGGESTION (G1, G2). They match merged repo patterns, and no output changes. The earlier proposal to expect VA 2022 = true in a new test is wrong after C1. SA2 has the corrected values.

Out of scope / follow-up

  • Iowa pregnancy income limit. IA-25-0019 cuts the limit "from 375% to 215% of the FPL" from 2025-04-01 (#page=5), but pregnant/income_limit.yaml:47-48 still has IA: 2018-01-01: 3.80. This value is pre-existing, and #10365 does not change it. Open a follow-up issue. The PR's IA tests use an income level of 1, so they do not depend on it.
  • CHIP postpartum gap. Tracked in issue #10362 and draft PR #10363, which reads is_pregnant_for_medicaid_nfc. Merge this PR first.
  • Continuous eligibility. The model applies the current-year pregnancy income test and does not model "enrolled while pregnant" (SHO 21-007 #page=2). This PR stretches that approximation from about 2 months to 12 months.
  • Lawfully residing group. The NJ and VA 1115s start the extension for the CHIPRA 214 group on 2022-04-01. Under the January 1 read, NJ gives that group 12 months in annual 2022. This is a historical year with a very small population.
  • Future end dates. The Utah 1115 ends 2027-06-30 and the NJ demonstration ends 2028-06-30. Recheck both at renewal.
  • Other. Territories resolve to 0 through the breakdown default. under_60_days_postpartum.py:8 has unit = USD on a bool. count_days_postpartum has no test file of its own. The Tennessee Medicaid-side source is a state notice, because no CMS TennCare III document was found. Both cited documents give 2022-04-01. The Illinois 1115 PDF is on a state site, so it has the same link-rot risk as the NJ link.

PDF Audit Summary

Source group Documents read (file pages) Result
CMS SPA approval letters 45 states plus IA-25-0018, KS-22-0016, UT-25-0024, IL-22-0020, TN-22-0021; letter page of each (p.1 for AL and ND, p.3 for LA, MI, SC and SD, otherwise p.2) 0 wrong dates, 0 wrong anchors
Manifest PDFs (300 dpi) WI-26-0014 pp.2-5, IA-25-0018 pp.2, 4, 5, 17, UT-25-0024 pp.2-5, 7, TX-23-0028 pp.2, 4, 5, 7, SC-22-0004 pp.3-5, 14, plus MO-23-0022 p.2 and IA-25-0019 p.2 21 matches, 0 mismatches
Section 1115 approvals FL pp.1-2, IL pp.1, 12, NJ 2021 p.1, VA pp.1, 4, 7, 8, 10, 18, UT pp.1, 3, 10, 26, 90 FL, IL and UT correct; VA date wrong (C1); NJ authority ends 2022-06-30 (C2)
Coverage-start and renewal evidence VA semi-annual report p.12, DMAS FAQ p.1, VCU p.1; NJ temporary extensions p.1 (x3), 2023 extension pp.1, 2, 27, 77; HFS report pp.1-3, 6 VA began 2022-07-01; NJ continuous to 2028-06-30; IL live in 2021
State documents FL SB 2526 pp.11-12, 21; TennCare notice p.1 Correct
Federal 42 USC 1396a(e)(5), (e)(16) and the ARPA note; SHO 21-007 pp.2, 4, 7; CA-22-0030 p.8 (S-page) Correct; anchor precision (G1); CA test name (SA1)
Per-jurisdiction results (51)
State 365 from (repo) Approval cited (file page) Result
AK 2024-02-01 AK-24-0001 p.2 Match
AL 2022-10-01 AL-22-0007 p.1 Match
AR none (60) 42 USC 1396a(e)(5); no election (KFF, 2026-07-15) Correct (60 only)
AZ 2023-04-01 AZ-22-0009 p.2 Match
CA 2022-04-01 CA-22-0030 p.2 Match
CO 2022-07-01 CO-22-0009 p.2 Match
CT 2022-04-01 CT-22-0016 p.2 Match
DC 2022-04-01 DC-22-0001 p.2 Correct (KFF links DE-22-0011 in error)
DE 2022-07-01 DE-22-0011 p.2 Match
FL 2022-07-01 FL 1115 letter p.1; SB 2526 s.11 p.21 Correct (letter defers to SB 2526)
GA 2022-11-01 GA-22-0005 p.2 Match
HI 2022-04-01 HI-22-0008 p.2 Match
IA 2025-04-01 IA-25-0018 p.2; IA-25-0019 p.2 Correct (IA-25-0018 superseded the Jan 1 date)
ID 2025-01-01 ID-25-0001 p.2 Match
IL 2021-04-12 IL 1115 letter p.1; IL-22-0020 p.2 Correct (cleared on re-check)
IN 2022-04-01 IN-22-0001 p.2 Match
KS 2022-04-01 KS-22-0015 p.2; KS-22-0016 p.2 Correct (0015 = election; 0016 = benefit plan)
KY 2022-04-01 KY-22-0002 p.2 Match
LA 2022-04-01 LA-22-0009 p.3 Match (untested, SA2)
MA 2022-04-01 MA-22-0014 p.2 Match
MD 2022-04-01 MD-22-0014 p.2 Match
ME 2022-08-01 ME-22-0016 p.2 Match
MI 2022-04-01 MI-22-0100 p.3 Match (untested, SA2)
MN 2022-07-01 MN-22-0008 p.2 Match
MO 2023-07-07 MO-23-0022 p.2 Match
MS 2023-04-01 MS-23-0015 p.2 Match
MT 2023-07-01 MT-23-0018 p.2 Match
NC 2022-04-01 NC-22-0012 p.2 Match
ND 2023-01-01 ND-22-0025 p.1 Match
NE 2024-01-01 NE-24-0003 p.2 Match
NH 2023-10-01 NH-23-0005 p.2 Match
NJ 2021-10-28 NJ 1115 letter p.1 Date correct; reference ends 2022-06-30 (C2)
NM 2022-04-01 NM-22-0013 p.2 Match
NV 2024-01-01 NV-23-0033 p.2 Match
NY 2023-03-01 NY-23-0006 p.2 Match
OH 2022-04-01 OH-22-0018 p.2 Match
OK 2023-01-01 OK-22-0042 p.2 Match
OR 2022-04-01 OR-22-0008 p.2 Match
PA 2022-04-01 PA-22-0016 p.2 Match
RI 2022-10-01 RI-22-0024 p.2 Match
SC 2022-04-22 SC-22-0004 p.3 Match
SD 2023-07-01 SD-23-0008 p.3 Match
TN 2022-04-01 TennCare notice p.1; TN-22-0021 p.2 Correct
TX 2024-03-01 TX-23-0028 p.2 Match
UT 2024-01-01 UT-23-0017 p.2; UT-25-0024 p.2; UT 1115 p.3 Correct; 365 continues from 2026-01-01 under the 1115
VA 2021-11-18 VA 1115 letter p.1, p.10; semi-annual report p.12 Wrong date (C1): coverage began 2022-07-01
VT 2023-04-01 VT-23-0004 p.2 Match
WA 2022-04-01 WA-22-0012 p.2 Match
WI 2026-06-01 WI-26-0014 p.2 Correct (KFF and Governor say July 1; same annual values)
WV 2022-04-01 WV-22-0007 p.2 Match
WY 2023-07-01 WY-23-0005 p.2 Match

Validation Summary

Check Result
CI 27/27 pass at e6cca57c59
Local tests is_pregnant_for_medicaid.yaml 22/22; gov/hhs/medicaid/eligibility 424/424
Partner contract tests None edited. Read-only run of partners/analytics_coverage/edge_cases/federal/healthcare: 70/70
Regulatory 1 critical (C1). Statute, ARPA 9812(b) floor (2022-04-01), no sunset (CAA 2023 5113) and SHO 21-007 CHIP reading all consistent with the PR
References 58 entries: 0 wrong dates in SPA states, 0 wrong #page= anchors; 1 non-corroborating reference (NJ after 2022-06-30, C2); 1 imprecise anchor (G1)
Code patterns No .py file in the diff. YAML: 51 sorted keys, ascending dates, integer values, every PDF href has #page=. Changelog fragment is top-level and typed fixed
Tests 10 new cases, all correct by hand check. Gaps: LA/MI/VA (SA2), composite-only asserts (G5), same-year and target-year edges (G6). Proposed YAML for SA1, SA2, G2, G6 and G7: 12 cases run at the head, all pass (VA in SA2 as at the head)
Probes VA mutation (365 from 2022-07-01): only annual 2022 changes; eligibility flips between 138% and 148% FPL
Microsimulation policyengine-us-data sets no postpartum input, so population impact is nil today; household results change
Branch 5 ahead / 14 behind main; MERGEABLE. Overlap with #10365 in T
Other reviews None on the PR

Review Severity: REQUEST_CHANGES

Two critical items (C1, C2) and two should-address items (SA1, SA2) are open.

Next Steps

To auto-fix issues: run the fix-pr workflow for this PR.

  1. Apply C1 (VA date, reference, comment, PR body row, changelog wording).
  2. Apply C2 (NJ references and the PR body sentence).
  3. Apply SA1 (CA test name and comment) and SA2 (LA, MI and VA cases, after C1).
  4. Take the suggestions you agree with. G1 to G5 are small edits, and G6 and G7 are pre-run test YAML.
  5. Run make format and the T file and the eligibility folder again.
  6. Not assessed by the review delegates: the PR body has no axiom: line, and CLAUDE.md:158-159 (since #9641) asks for one on a policy change. Add it when you update the body.

hua7450 and others added 2 commits October 23, 2026 22:24
…es, tests

- Virginia's 12-month postpartum coverage starts July 1, 2022, when DMAS
  implemented it, not on the November 18, 2021 section 1115 approval date.
- Cite the New Jersey temporary extensions and the 2023-2028 renewal, so
  365 days is supported after June 30, 2022.
- Point the statute reference at 1396a(e)(16), document the January 1 read
  and day-365 cutoff, and refine the description, label and unit.
- Use the official medicaid.gov copy of the New Jersey 2021 letter and add
  page lists for Florida SB 2526 and the Utah 1115.
- Rename the CA boundary test, add LA, MI and VA cases for 2022 and 2023,
  ID 2024/2025 and UT 2026 cases, give the TX cases their own units, and
  assert the postpartum output, category and eligibility.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>

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Program Review

PR #10241, "Date 12-month Medicaid postpartum coverage from each state's approval" (hua7450). Round 2, incremental review of the changes since round 1.

IDs: C = critical, SA = should address, G = suggestion. Round-1 IDs keep their numbers. New suggestions start at G12.

Paths: P = policyengine_us/parameters/gov/hhs/medicaid/eligibility/categories/pregnant/postpartum_coverage.yaml, T = policyengine_us/tests/policy/baseline/gov/hhs/medicaid/eligibility/categories/is_pregnant_for_medicaid.yaml, L = policyengine_us/tests/policy/baseline/gov/hhs/medicaid/eligibility/is_medicaid_lawfully_residing_option_eligible.yaml. Line numbers refer to the reviewed head. Every PDF link uses the file page number, not the printed page number.

Source Documents

Branch Status

  • The branch is 7 commits ahead and 31 behind main (0e7ced1747), and it is MERGEABLE. The 31 commits change no Medicaid pregnancy or postpartum path and do not change CLAUDE.md. The staleness did not affect any finding.
  • The merge of main into the branch changed medicaid/income/medicaid_person_is_required_to_file.py. The new TX medicaid_category and is_medicaid_eligible asserts still pass after it.
  • Merge order: #10365 (same author, still open) also edits is_pregnant_for_medicaid.yaml. A trial merge gives one append/append conflict at T:141 (this PR's 15 cases against #10365's 4 WV cases). A resolution that keeps both blocks passes with #10365's files in place: 192 of 192 (T 31 cases plus gov/hhs/chip 161). The PR that merges second must keep both blocks.
  • CHIP draft #10363 reads is_pregnant_for_medicaid_nfc. Merge this PR first.

What round 2 fixed

The author applied both critical items and both should-address items, almost word for word. The author applied ten of the eleven suggestions and part of the eleventh (G6).

  • C1 (Virginia). P:274-279 is now 2022-07-01: 365 with the proposed comment. P:128-131 cites the 1115 letter at pages 1 and 10 and the DMAS monitoring report at page 12. A probe against a copy with the round-1 date shows that only annual 2022 changes. The new LA/MI/VA 2022 case fails if the date goes back to 2021-11-18, so the date is pinned.
  • C2 (New Jersey). P:84-91 adds the three CMS temporary extensions and expenditure authority 6 of the 2023-2028 approval. Each letter was signed before the earlier authority expired. The authority is therefore continuous from 2021-10-28 to 2028-06-30, and each annual read (2022, 2023, and 2024 onward) has a source.
  • SA1 (CA test). T:215-219 has the proposed comment and name. The inputs and expected values did not change, and the case now also asserts is_pregnant_for_medicaid_nfc.
  • SA2 (LA, MI and VA tests). T:403-515 adds the two proposed cases: [false, false, false] in 2022 and [true, true, true] in 2023, for both outputs. They pin the three dates and the base 60 for LA.
  • References. 19 of 19 page and anchor checks on the new and changed entries are correct. 14 pages were read as images. The NJ, VA, FL and UT entries follow CLAUDE.md:151-155.
  • Tests. 15 cases are appended (10 from round 1 and 5 new). All are correct by hand check. A mutation run on P killed 14 of 21 mutants. Of the 7 survivors, 1 is equivalent under the January 1 read, 3 are value typos that the realistic input cannot detect, 1 needs a New Jersey gap that no source supports, and 2 are caught by the cases in G12.
  • Runs. CI passes 32 of 32. Local runs: T 27 of 27, the eligibility folder 429 pass, and the read-only partner healthcare folder 70 of 70.

Round-1 status

ID Status Evidence
C1 RESOLVED VA is 2022-07-01: 365 with the comment (P:274-279). The references at P:128-131 are correct on the page images. The changelog, the body row and the Virginia note are updated. Only annual 2022 moves.
C2 RESOLVED P:84-91 adds ca1, ca2 and ca3 (page 1) and expenditure authority 6 (page 27), as proposed. There is no gap to 2028-06-30. The body cites EA 6 without STC 5.15, which is enough, because EA 6 states the rule.
SA1 RESOLVED T:215-219 name and comment as proposed. [true, false] is unchanged, and _nfc is added.
SA2 RESOLVED T:403-515 as proposed. Both cases pass and pin the LA, MI and VA dates.
G1 RESOLVED One statute entry with href #e_16 (P:14-15). The anchor exists.
G2 RESOLVED The TX cases have spm, family and per-person marital units (T:160-170, T:194-204). The outputs did not change.
G3 RESOLVED The NOTE at P:2-7 has the proposed text. It is accurate against the statute and the formula.
G4 RESOLVED Description and label as proposed (P:1, P:10). The unit was already day. G15 refines the review's own description wording.
G5 RESOLVED _nfc is asserted at all six places with the proposed values. The optional age: 28 unification was not done. That is defensible, because no asserted variable reads age.
G6 PARTIAL ID 2024, ID 2025 and UT 2026 were added as proposed (T:517-549). The two AR cases were not added, and no reason was given. Leaving out the AR under_12_months_postpartum case is defensible, because it repeats the TX 2024 path (60 < 60). The AR 59-day case moves into G12.
G7 RESOLVED TX category and eligibility asserts added (T:178-179, T:212-213). They pass after the main merge. The optional 2027 work-requirement pair was not added, which is acceptable.
G8 RESOLVED The comment at T:28-29 matches the proposal.
G9 RESOLVED The NJ 2021 href is the medicaid.gov copy (P:83). It is live, and page 1 is the CMS letter. The body note is updated.
G10 RESOLVED FL title "sections 6 and 11 #page 11-12,21" with #page=11 (P:34-35) and UT title "#page 3,26,90" (P:124). All pages are correct. G14 corrects the body's reading of section 6, which came from the round-1 text.
G11 RESOLVED The Wisconsin note gives the July 1 go-live, the June 1 legal date and the same annual values.
Next Steps 6 (axiom: line, not rated in round 1) STILL OPEN Process note below. Not counted toward the verdict.

Critical (Must Fix)

None.

Should Address

None.

Process note (not counted): the PR body has no axiom: line

  • Where: the PR body. Rule: CLAUDE.md:158-162 ("Axiom Parity (required for policy changes)"), CONTRIBUTING.md:89-95 (#axiom-parity) and the PR template ("Required for any change to policy").
  • Evidence: The body has no axiom text. Round 1 (Next Steps 6) asked for the line. The author updated the body in round 2 but did not add the line, and gave no reason. No CI job checks the line, so the review is the only check. Other reviewers held #10319, #10333 and #10317 until a valid line was added, and since 2026-10-21 no policy PR merged without the line. This review does not count the line toward the verdict. Please add it before merge.
  • Why it applies: the PR changes policy output, namely the annual postpartum coverage period for 50 jurisdictions.
  • Valid form for this PR:
    • n/a: <reason> is not valid, because the PR changes policy output.
    • axiom: needed is for external contributors only. Reviewers rejected it for staff authors in #10317 and #10333.
    • rulespec-us us/statutes/42/1396a/e.yaml encodes the federal rule in (e)(16)(A)-(B) as extended_postpartum_coverage_period_months. It marks extended_postpartum_medical_assistance as not executable, because the rule depends on the state election. No rulespec-us issue covers the state election dates. A search for "postpartum" finds only #1474 (CHIP lawfully residing option) and the merged PR #536 (CHIP postpartum continuation).
    • The probable line is therefore a new dispatch-ready rulespec-us issue for the state election dates. Label it pe-parity, and give the module path, the corpus citation, the verbatim law, the required outputs and companion tests (CLAUDE.md:160, CONTRIBUTING.md:95). Take the companion expected values from the CMS approvals, not from policyengine-us output. queued is allowed only when the signed encoder is blocked, so record the blocker in the issue.
axiom: TheAxiomFoundation/rulespec-us#<issue> queued
  • The encoded-correct form is valid only if it names the module and a companion case in its .test.yaml that exercises the same situation as your YAML tests (CONTRIBUTING.md:94). us/statutes/42/1396a/e.yaml has no state election dates, so use this form only if you find such a case:
axiom: 42 USC 1396a(e)(16) encoded-correct

You choose the form. Either valid form makes the PR meet the rule.

Suggestions

G12. Pin Utah's 2024-01-01 start and Arkansas's 60 inside the period.

  • Where: P:271-273 (UT) and P:146-147 (AR). T:539-549 tests UT only in 2026, and T:260-268 tests AR only at 90 days.
  • Evidence: If UT's start moves to 2025-01-01, annual 2024 goes from 365 to 60, and every test in T and L still passes. The related suite of 1049 cases (gov/hhs/medicaid, gov/hhs/chip, gov/states/ms/dom/hmw, gov/usda/wic and the partner healthcare folder) also passes. The same is true if AR's 60 becomes 59. Only T and L set a postpartum input, so no other test can catch either change. The AR case is the remainder of G6.
  • Why a suggestion: both are per-state pins of the same class as the other SPA dates without a case, which round 1 accepted. Each formula edge already has a case: the strict < at 60 (T:30-44) and at 365 (T:219), a January 1 entry in the same year (T:529), and the UT change of legal basis (T:541).
  • Fix: both cases were run at the head and pass. Each one fails on the change that it pins. Put the UT case before the UT 2026 comment at T:539, so the UT cases are in date order:
# SPA UT-23-0017 takes effect on January 1, 2024, so annual 2024 applies
# 12 months in the same year.
- name: UT postpartum coverage extends to 12 months in 2024 under SPA UT-23-0017
  period: 2024
  input:
    state_code: UT
    count_days_postpartum: 90
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: true
    is_pregnant_for_medicaid: true

Put the AR case after the AR 90-day case (after T:268):

- name: AR postpartum coverage holds inside the 60-day period in 2026
  period: 2026
  input:
    state_code: AR
    count_days_postpartum: 59
    medicaid_income_level: 1
  output:
    is_pregnant_for_medicaid_nfc: true
    is_pregnant_for_medicaid: true

G13. Record New Jersey's later operational start beside the 2021-10-28 date.

  • Where: P:232-234 (NJ: 2021-10-28: 365) and the New Jersey bullet under "Source notes" in the PR body.
  • Evidence: The legal start is 2021-10-28. The approval is effective that day, and STC 43 has no deferral (#page=56). But DMAHS built the eligibility-system change during 2022. On January 27, 2022, DMAHS was "in the process of implementing" it (MAAC transcript, page 12). On July 12, 2022, "Phase 1 (Complete)" extended the coverage end date from 60 days to 12 months (MAAC deck, page 27). In its review of 2022, DMAHS said "we did implement this year" (MAAC transcript of February 1, 2023, page 19). No source publishes the go-live date. During the build, FFCRA continuous enrollment kept enrolled postpartum members covered.
  • Effect: a probe with any NJ date in 2022 changes only annual 2022 for NJ, from 365 to 60. T:362-401 then fails at the NJ position.
  • Why a suggestion and not the C1 class: Virginia's STCs deferred the start, and DMAS published "effective July 1, 2022". New Jersey's STCs have no deferral, and no exact date exists to encode. The PR's stated rule (the second Summary paragraph) dates each state from its approval unless the approval defers coverage, and NJ meets that rule. In 2022, NJ members were in fact covered.
  • Fix (no value change). In P:
NJ:
  2021-01-01: 60
  # The section 1115 amendment took effect 2021-10-28 with no deferred start
  # (STC 43). DMAHS completed the eligibility-system change during 2022, and
  # FFCRA continuous enrollment kept postpartum enrollees covered meanwhile.
  2021-10-28: 365

In the body New Jersey note, add: "DMAHS reported that it built the system change during 2022 (MAAC, January 27 and July 12, 2022; February 1, 2023), while FFCRA continuous enrollment kept postpartum members covered. The model uses the 2021-10-28 legal effective date, because the STCs do not defer the start and no go-live date is published."

G14. The Florida body note reads SB 2526 section 6 as the Medicaid change, but section 6 is the CHIP (Kidcare) change.

  • Where: the Florida bullet under "Source notes" in the PR body. The reference at P:34-35 is correct and does not change.
  • Evidence: Section 6 adds s. 409.814(4). A "Title XXI-funded child who reaches 19 years of age" keeps Title XXI coverage through "the 12-month period beginning on the last day of a pregnancy" (#page=11, pages 11-12, images). s. 409.814 is in the Florida Kidcare Act (ss. 409.810-409.821). No SB 2526 section amends s. 409.903 or 409.904. The Medicaid 12-month rule came from ch. 2021-41 s. 5 (SB 2518, 2021), which amended s. 409.903(5). The CMS letter says that "Florida's initial enacting legislation for the 12-month postpartum extension did not address CHIP coverage", and it makes the extension effective upon the effective date of SB 2526 (#page=2). The round-1 G10 text ("The substantive 12-month change is section 6") is the source of this reading.
  • Why the reference still holds: the letter makes the Medicaid start depend on SB 2526. Section 6 is the condition that CMS named, and section 11 gives the date, 2022-07-01. The title does not call section 6 the Medicaid change, so it still supports FL: 2022-07-01: 365.
  • Fix (body only): "CMS approved the 1115 amendment on 2022-05-25, but the letter delays the extension until Florida SB 2526 takes effect (pages 1-2). SB 2526 section 6 adds s. 409.814(4), which keeps Title XXI (Kidcare) coverage through the 12-month postpartum period for enrollees who turn 19 (pages 11-12). CMS required this CHIP change before the Medicaid extension could start. Section 11 makes the act effective 2022-07-01 (page 21). The Medicaid 12-month rule is in s. 409.903(5), as amended by ch. 2021-41 (SB 2518, 2021)." Optional: cite s. 409.903(5) or ch. 2021-41 in P. The current FL references already support the date.

G15. The description says "pregnancy-related coverage", but the 12-month period carries full benefits.

  • Where: P:1. The text came from the round-1 G4 proposal, so this corrects the review's own wording.
  • Evidence: For the 60-day value, (e)(5) gives "pregnancy-related and postpartum medical assistance", so the phrase fits. For the 365-day value, (e)(16)(B)(i) requires "all items and services covered under the State plan". The FL letter says that electing states "may not limit coverage to pregnancy-related services" under 42 CFR 435.116(d)(3) (#page=2), and SHO 21-007 says the same (#page=6). A reader can take "pregnancy-related coverage" as that limited package. The model encodes a day count, not a service package, so no output changes.
  • Fix:
description: States continue eligibility as though the individual were still pregnant for this number of days after a pregnancy ends under the Medicaid program.

This follows (e)(5) ("as though she were pregnant") and 42 CFR 435.4, and it describes what is_pregnant_for_medicaid_nfc does for both values.

G16. Two small wording points in the PR body.

  • "Review changes (round 1)", third bullet: "the unit is day". Commit 2a357f397a also says "refine the description, label and unit". The unit did not change; it was day before the PR. Write "the unit stays day", or remove the clause. Do not rewrite the commit.
  • "Review changes (round 1)", first bullet: "a Virginia woman 61 to 365 days postpartum gets the 60-day rule that year". In the model, the affected inputs are count_days_postpartum 60 to 364. Write "a Virginia woman at day 60 or later of the 12-month period".

Investigated and cleared

  • Virginia move. Only annual 2022 changes. All readers of is_pregnant_for_medicaid_nfc are YEAR-defined, so no other year can move.
  • Changelog wording, "the dates their extensions took effect". It matches every encoded date: IL, LA, MI, NJ (legal date, see G13), VA, FL, UT and WI.
  • NOTE at P:2-7. Accurate. (e)(5) and (e)(16)(A) both run to the end of the month. The strict < comparison stops at day 60 or day 365. NJ EA 6 and UT STC 4.3(i) use the same end point.
  • Florida reference after G10. It still supports 2022-07-01 (see G14).
  • New Jersey legal date. 2021-10-28 is defensible. G13 only adds a comment.
  • Other surviving mutants. Moving ID's start one day earlier, to 2024-12-31, is equivalent under the January 1 read. A change of LA or TX 365 to 364 or 91 cannot be detected with the realistic input (under_12_months_postpartum maps to 60), and the 365 boundary is pinned for CA (T:219) and NJ (L). An NJ gap from 2022-07-01 to 2023-04-01 survives, but no source supports a gap, and L catches a permanent removal. No action.
  • TX asserts after the main merge. They pass (T 27 of 27).
  • PR body test claims. "Fifteen cases" is 10 plus 5. Every new case asserts _nfc. The existing postpartum cases are unchanged. No partner test sets a postpartum input. All accurate.
  • period: metadata in P. Absent at the head and on main. Pre-existing, so not raised.

Out of scope / follow-up

Carried from round 1, with no new evidence:

  • Iowa pregnancy income limit. IA-25-0019 cuts the limit from 375% to 215% of the FPL from 2025-04-01 (#page=5), but pregnant/income_limit.yaml:47-48 still has IA: 2018-01-01: 3.80. Open a follow-up issue. The PR's IA tests use an income level of 1, so they do not depend on it.
  • CHIP postpartum gap. Tracked in issue #10362 and draft PR #10363, which reads is_pregnant_for_medicaid_nfc. Merge this PR first.
  • Continuous eligibility. The model applies the current-year pregnancy income test and does not model "enrolled while pregnant". This PR stretches that approximation from about 2 months to 12 months.
  • Lawfully residing group. The NJ and VA 1115s start the extension for the CHIPRA 214 group on 2022-04-01. Under the January 1 read, NJ gives that group 12 months in annual 2022. This is a historical year with a very small population.
  • Future end dates. The Utah 1115 ends 2027-06-30, and the NJ demonstration ends 2028-06-30. Recheck both at renewal.
  • Other. Territories resolve to 0 through the breakdown default. under_60_days_postpartum.py:8 has unit = USD on a bool. count_days_postpartum has no test file of its own. The Tennessee Medicaid-side source is a state notice. The Illinois 1115 PDF is on a state site, with the same link-rot risk that the NJ link had.

New in round 2:

  • Sibling PRs. #10364 and #10365 also have no axiom: line. Both carry the same request.

PDF Audit Summary

Source group Documents read (file pages) Result
Virginia 1115 amendment pp.1, 10; monitoring report p.12; DMAS FAQ p.1 Approval 2021-11-18, ramp-up clause, coverage from 2022-07-01: C1 fix correct
New Jersey authority 2021 amendment p.1, STC 43 pp.56-57; ca1, ca2, ca3 p.1; 2023 approval pp.1, 27, 77 Continuous 2021-10-28 to 2028-06-30: C2 fix correct
New Jersey implementation MAAC transcripts (2022-01-27 p.12, 2023-02-01 p.19), MAAC deck (2022-07-12 p.27), renewal proposal p.29, quarterly reports p.2 System change built during 2022, no published go-live date (G13)
Florida 1115 letter pp.1-2; SB 2526 pp.1-2, 11, 12, 21; ch. 2021-41 pp.1, 5 Date and reference correct; body reading of section 6 (G14)
Utah 1115 amendment pp.3, 26, 90 Table 8 gives 1/1/2026: G10 title correct
Federal 42 USC 1396a(e)(5), (e)(16); 42 CFR 435.4, 435.116(d); SHO 21-007 pp.2, 6, 7, 19, 21 Statute anchor and NOTE correct; description wording (G15)

Validation Summary

Check Result
CI 32/32 pass at 8f7c416c14
Local tests T 27/27; T + L 49/49; gov/hhs/medicaid/eligibility 429 pass
Partner contract tests None edited. Read-only run of partners/analytics_coverage/edge_cases/federal/healthcare: 70/70
References 63 entries (58 plus 5 new). 19 of 19 page and anchor checks on new and changed entries correct (14 read as images). No non-corroborating reference
Regulatory C1 and C2 fixed. NOTE accurate. NJ legal against operational start (G13). FL section 6 reading in the body (G14)
Code patterns YAML only. 51 sorted keys, ascending dates, integer values. Description, label and NOTE placement follow repo patterns. Changelog is top-level, typed fixed, and its new wording is accurate
Tests 15 appended cases, all correct by hand check
Mutation 21 mutants of P: 14 killed, 1 equivalent, 6 survive (2 caught by G12, 4 accepted)
Probes VA move: only annual 2022 changes. NJ date anywhere in 2022: only annual 2022 for NJ changes
Merge trial with #10365 One append/append conflict in T. A resolution that keeps both blocks: 192/192
Microsimulation policyengine-us-data sets no postpartum input, so the population impact is nil today. Household results change
Branch 7 ahead / 31 behind main; MERGEABLE
PR body No axiom: line (process note). Two wording points (G16)
Other reviews None on the PR

Review Severity: APPROVE

No critical or should-address item is open. Five suggestions are open (G12 to G16). The missing axiom: line is a process note: add it before merge.

Next Steps

To auto-fix issues: run the fix-pr workflow for this PR.

  1. Add a valid axiom: line to the PR body before merge (process note above). The model, references and tests need no further change.
  2. Take the suggestions that you agree with. G12 is pre-run test YAML. G13 is a comment in P and one body sentence. G14 and G16 change the body only. G15 is one line in P.
  3. If you change P or T, run make format, and run T and the eligibility folder again.
  4. When #10365 merges, keep both test blocks in T, whichever PR merges second.

…rsey start note, description

- Add a Utah 2024 case (SPA UT-23-0017 from 2024-01-01) and an Arkansas
  59-day case so both values are pinned.
- Note beside the New Jersey date that the section 1115 amendment had no
  deferred start and DMAHS finished the system change during 2022.
- Describe the parameter as continued eligibility "as though" still
  pregnant, which fits both the 60-day and the 12-month periods.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
hua7450 added a commit to hua7450/policyengine-us that referenced this pull request Oct 26, 2026
- Case 10 and Case 15 comments give Virginia's FAMIS MOMS extension as
  approved November 18, 2021 and implemented July 1, 2022, matching the
  Medicaid date in PolicyEngine#10241.
- Case 8 comment dates Colorado's FCEP option from January 1, 2025, as
  in PolicyEngine#10365.
- Case 9 comment states the Colorado Medicaid and CHIP pregnancy limits
  before the 5 percentage point MAGI disregard.
- Case 12 also asserts medicaid_category [PREGNANT, NONE].

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
@hua7450
hua7450 merged commit 0e659c8 into main Oct 27, 2026
62 of 64 checks passed
@hua7450
hua7450 deleted the medicaid-postpartum-12-month branch October 27, 2026 01:35
hua7450 added a commit that referenced this pull request Oct 27, 2026
Resolve is_pregnant_for_medicaid.yaml by keeping main's postpartum cases
from #10241 and appending this branch's West Virginia cases.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
hua7450 added a commit that referenced this pull request Oct 27, 2026
…-dates' into fix-ri-pregnancy-medicaid-pathways

Brings in #10365's head ae4dc7a, which includes main with #10241.
is_pregnant_for_medicaid.yaml keeps main's #10241 cases and #10365's West
Virginia cases, followed by this branch's Rhode Island block.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
hua7450 added a commit that referenced this pull request Oct 27, 2026
Main's #10241 cases now precede the block, so Cases 17-23 become 34-40.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
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Date 12-month Medicaid postpartum coverage by state

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