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Date 12-month Medicaid postpartum coverage from each state's approval - #10241
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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
- PDF: CMS approval, Wisconsin SPA WI-26-0014 (16 pages; pages 2-5 read)
- PDF: CMS approval, Iowa SPA IA-25-0018 (17 pages; pages 2, 4, 5, 17) and IA-25-0019 (page 2)
- PDF: CMS approval, Utah SPA UT-25-0024 (7 pages; pages 2-5, 7), UT-23-0017 (pages 2, 7) and the Utah Medicaid Reform 1115 amendment (304 pages; pages 1, 3, 10, 26, 90)
- PDF: CMS approval, Texas SPA TX-23-0028 (8 pages; pages 2, 4, 5, 7)
- PDF: CMS approval, South Carolina SPA SC-22-0004 (14 pages, scanned; pages 3-5, 14)
- PDF: the other 42 CMS SPA approval letters cited in
P(including CHIP SPA TN-22-0021), each read on its letter page (see the PDF Audit Summary) - PDF: Virginia FAMIS MOMS and FAMIS Select 1115 amendment (67 pages; pages 1, 4, 7, 8, 10, 18), Virginia semi-annual monitoring report, July-December 2023, DMAS provider FAQs, VCU infographic (1 page)
- PDF: New Jersey 1115 amendment, 2021, CMS temporary extensions of June 7, 2022, November 28, 2022 and January 26, 2023, and the 2023-2028 extension approval (300 pages; pages 1, 2, 27, 77)
- PDF: Illinois Continuity of Care 1115 amendment (44 pages; pages 1, 12), HFS annual monitoring report (pages 1-3, 6), IL-22-0020
- PDF: Florida MMA 1115 amendment (105 pages; pages 1-2) and Florida SB 2526 (2022), enrolled (pages 11-12, 21)
- PDF: CMS SHO 21-007 (22 pages; pages 2, 4, 7)
- Web: 42 U.S.C. 1396a(e)(5) and (e)(16), with the ARPA 9812(b) / CAA 2023 5113 note
- Web: KFF postpartum coverage extension tracker (as of 2026-07-15; cross-check only) and the Wisconsin Governor's release of July 1, 2026
- Year: target 2026. The PR's effective dates run from 2021-04-12 to 2026-06-01; its tests cover 2021-2027.
- Scope: Full. Three files:
changelog.d/medicaid-postpartum-12-month.fixed.md,PandT(399 insertions, 7 deletions against merge base2bc4ccc970). - Reviewed head SHA: e6cca57
- Mode: full
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.yamland 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), referenceP: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: 365Replace 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=12Add 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 atP:216-218are 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:76-77and 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=27In 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_coveragecomparison. Your PR body (line 91) and the file header (T:139-140) say the same thing. The repo already names this convention correctly inis_medicaid_lawfully_residing_option_eligible.yaml:162-166. - Fix: replace
T:187-188with 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 limitDo 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 givestruein 2022 until C1 is applied. A probe with VA at 2022-07-01 givesfalsein 2022 andtruein 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_16If 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 periodG5. 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: falseG7. 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=1Update 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=3G11. 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 =
truein 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:47-48still hasIA: 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:8hasunit = USDon a bool.count_days_postpartumhas 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.
- Apply C1 (VA date, reference, comment, PR body row, changelog wording).
- Apply C2 (NJ references and the PR body sentence).
- Apply SA1 (CA test name and comment) and SA2 (LA, MI and VA cases, after C1).
- Take the suggestions you agree with. G1 to G5 are small edits, and G6 and G7 are pre-run test YAML.
- Run
make formatand theTfile and the eligibility folder again. - 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.
…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>
PavelMakarchuk
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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
- Reviewed head SHA: 8f7c416
- Mode: incremental from e6cca57 (round 1, CHANGES_REQUESTED)
- Scope: 3 files, 216 insertions and 12 deletions since round 1. All of it comes from commit
2a357f397a("Fix issues from review ..."). The later merge ofmain(8f7c416c14) changes none of the three files. - PDF: Virginia FAMIS MOMS and FAMIS Select 1115 amendment (pages 1, 10), semi-annual monitoring report, July-December 2023 (page 12), DMAS provider FAQ (page 1). All read as images.
- PDF: New Jersey 2021 amendment, medicaid.gov copy (483 pages; page 1 as image, STC 43 on pages 56-57), CMS temporary extensions ca1, ca2 and ca3 (page 1 each, images), and the 2023-2028 extension approval (pages 1 and 27 as images, page 77).
- PDF: New Jersey implementation record: MAAC meeting transcripts of January 27, 2022 (page 12) and February 1, 2023 (page 19), and the MAAC slide deck of July 12, 2022 (page 27), all read as images from Wayback captures because nj.gov removed the originals; the NJ FamilyCare renewal proposal of February 28, 2022 (page 29); the NJ quarterly reports for October-December 2021 and for the quarter that medicaid.gov lists as January-March 2022 (page 2); the Rutgers evaluation design for 2023-2028 (pages 10, 290).
- PDF: Florida MMA 1115 amendment (pages 1-2, images), Florida SB 2526 (2022), enrolled (pages 1-2, 11, 12, 21, images), Laws of Florida ch. 2021-41 (SB 2518, 2021) pages 1 and 5, Fla. Stat. ss. 409.810, 409.903 and 409.904.
- PDF: Utah Medicaid Reform 1115 amendment (pages 3, 26, and 90 as image), CMS SHO 21-007 (pages 2, 6, 7, 19, 21).
- Web: 42 U.S.C. 1396a(e)(5) and (e)(16), 42 CFR 435.4 and 42 CFR 435.116(d).
- Repository and process:
CLAUDE.md:158-162,CONTRIBUTING.md:89-95,.github/PULL_REQUEST_TEMPLATE.md:12-13; rulespec-usus/statutes/42/1396a/e.yamland its issues; the review history of merged policy PRs #10249, #10288, #10317, #10319, #10333 and #10353. - Year: target 2026. The tests cover 2021-2027.
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
maininto the branch changedmedicaid/income/medicaid_person_is_required_to_file.py. The new TXmedicaid_categoryandis_medicaid_eligibleasserts 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 atT: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 (T31 cases plusgov/hhs/chip161). 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:274-279is now2022-07-01: 365with the proposed comment.P:128-131cites 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:84-91adds 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:215-219has the proposed comment and name. The inputs and expected values did not change, and the case now also assertsis_pregnant_for_medicaid_nfc. - SA2 (LA, MI and VA tests).
T:403-515adds 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
Pkilled 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:
T27 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
axiomtext. 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: neededis for external contributors only. Reviewers rejected it for staff authors in #10317 and #10333.- rulespec-us
us/statutes/42/1396a/e.yamlencodes the federal rule in (e)(16)(A)-(B) asextended_postpartum_coverage_period_months. It marksextended_postpartum_medical_assistanceas 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.queuedis allowed only when the signed encoder is blocked, so record the blocker in the issue.
axiom: TheAxiomFoundation/rulespec-us#<issue> queued
- The
encoded-correctform is valid only if it names the module and a companion case in its.test.yamlthat exercises the same situation as your YAML tests (CONTRIBUTING.md:94).us/statutes/42/1396a/e.yamlhas 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) andP:146-147(AR).T:539-549tests UT only in 2026, andT:260-268tests 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
TandLstill passes. The related suite of 1049 cases (gov/hhs/medicaid,gov/hhs/chip,gov/states/ms/dom/hmw,gov/usda/wicand the partner healthcare folder) also passes. The same is true if AR's 60 becomes 59. OnlyTandLset 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: truePut 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: trueG13. 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:362-401then 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: 365In 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:34-35is 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". Commit2a357f397aalso says "refine the description, label and unit". The unit did not change; it wasdaybefore the PR. Write "the unit staysday", 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_postpartum60 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_nfcare 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_postpartummaps 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, andLcatches a permanent removal. No action. - TX asserts after the
mainmerge. They pass (T27 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 inP. Absent at the head and onmain. 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:47-48still hasIA: 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:8hasunit = USDon a bool.count_days_postpartumhas 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:
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.
- Add a valid
axiom:line to the PR body before merge (process note above). The model, references and tests need no further change. - Take the suggestions that you agree with. G12 is pre-run test YAML. G13 is a comment in
Pand one body sentence. G14 and G16 change the body only. G15 is one line inP. - If you change
PorT, runmake format, and runTand the eligibility folder again. - 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>
- 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>
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>
…-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>
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>
Fixes #10464
Summary
postpartum_coverage.yamlset 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. Onmainthe result isfalse; with this PR it istrue(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
mainSource notes
count_days_postpartumcannot represent a 6-month period anyway:under_12_months_postpartummaps to 60 days.Modeling notes
is_pregnant_for_medicaid_nfcis 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.count_days_postpartum < limitcomparison 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) testsis_pregnantonly and applies no postpartum period at all, not even 60 days.is_chip_fcep_eligible_personalso applies none, which is consistent with the unborn-child option. I left the CHIP gap for #10362 (PR #10363).Out of scope
count_days_postpartumis an undated day count, so the model stops at day 60 or 365; the parameter's NOTE records this.Merge order
Merge this PR before #10363, which reads
is_pregnant_for_medicaid_nfc. #10365 also appends tois_pregnant_for_medicaid.yaml; whichever PR merges second keeps both blocks.Tests
Seventeen cases were appended to
is_pregnant_for_medicaid.yaml: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.count_days_postpartum < 365cutoffNew cases assert
is_pregnant_for_medicaid_nfcbesideis_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)
day, and a comment states the January 1 read and the day-365 cutoff.Review changes (round 2)
NJ: 2021-10-28: 365records that the amendment has no deferred start and that DMAHS finished the system change during 2022. The value did not change.axiom: TheAxiomFoundation/rulespec-us#1928 queued
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