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End Virginia's 12-month postpartum period for lawfully residing pregnant people on March 31, 2027 (FAMIS MOMS STC 17.c.iv) #10469

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@hua7450

Parameter to amend: Virginia postpartum period for lawfully residing pregnant people

Virginia's FAMIS MOMS and FAMIS Select section 1115 terms limit 12-month postpartum coverage for lawfully residing pregnant people (the CHIPRA section 214 option) to April 1, 2022 through March 31, 2027. The model applies Virginia's 365-day postpartum period to them with no end date.

Sources

  • STC 17.c.iv of the November 18, 2021 approval (page 17): lawfully residing individuals "are only eligible for continuous 12-month postpartum coverage in accordance with sections 9812 and 9822 of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2), for a five-year period starting April 1, 2022 through March 31, 2027."
  • Title XXI expenditure authorities 3 and 4 in the same approval (page 5) carry the same limit for CHIP lawfully residing pregnant individuals. The Title XIX authorities on page 6 carry it for Medicaid.
  • Still current. CMS's monitoring redesign overlay letter of June 25, 2025 reprints the STCs, and they keep the March 31, 2027 limit (PDF pages 5, 6 and 17). The demonstration's medicaid.gov page, checked 2026-10-26, lists no amendment after the November 18, 2021 approval. The demonstration itself runs to June 30, 2029.
  • Federal law. The current text of 42 USC 1396a(e)(16) has no end date; the Consolidated Appropriations Act, 2023 made the ARP option permanent. Whether CMS will lift the STC limit, or whether it lapses for these enrollees on April 1, 2027, is unresolved.

Model today

Proposed fix (if the limit stands)

Add a postpartum period for the lawfully residing option, with Virginia set to 60 days from 2027-04-01. Read it in is_medicaid_lawfully_residing_option_eligible and is_chip_immigration_status_eligible. Do not date a change on postpartum_coverage itself: that would cut every Virginia enrollee, whose authority runs to 2029.

Also check whether New Jersey's FamilyCare section 1115 terms, which cover CHIP lawfully residing pregnant women from April 1, 2022, carry a similar end date.

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