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Section 1115 Postpartum Coverage Demonstration Waiver

The Wisconsin Department of Health Services has submitted a Section 1115 Demonstration Waiver to the Centers for Medicare & Medicaid Services (CMS) to extend postpartum Medicaid coverage from 60 days to 90 days, as authorized by 2021 Wisconsin Act 58.

Below is information on the timeline for submission and public hearings on the waiver. Additional information about Section 1115 Demonstrations can be found on the CMS website.

March 15, 2022 | Tribal notice
April 6, 2022 | Public notice and draft waiver application posted to DHS website
April 13 and April 20, 2022 | Public hearings
May 10, 2022 | Tribal consultation
April 6 - May 6, 2022 | Public comment period
June 3, 2022 | Final waiver application submitted to CMS
TBD | CMS approval
As soon as possible after CMS approval | Implementation

Two public hearings were held to solicit comments on the postpartum coverage waiver. Due to the public health emergency related to the COVID-19 pandemic, DHS conducted webinars in place of in-person hearings.

Download the presentation: English (PDF) | Spanish (PDF) | Hmong (PDF)

Summary

Written comments on the proposed changes were accepted from April 6, 2022, through May 6, 2022, and were included in the waiver request submitted to CMS. All of the comments, except for four, were in support of the waiver. 

  • While still supporting the waiver, several commenters recommended that DHS extend the duration of coverage from the proposed three months to twelve months. These commenters suggested that a longer duration would align with the passage of the American Rescue Plan Act (ARPA) to provide 12-months of continuous Medicaid and CHIP coverage for pregnant and postpartum individuals, align with the recommendations of some healthcare organizations and further support the healthcare of new postpartum people. DHS Response: The authorizing legislation 2021 Wisconsin Act 58 authorizes Medicaid coverage for postpartum people for a period of three months following the date a pregnancy ends. This legislation does not allow for a duration of twelve months
  • Several commenters agreed that extending postpartum coverage to ninety days will positively impact health outcomes for postpartum people, support families, and begin to address racial health disparities.
  • Several commenters agreed that continuity of postpartum health care coverage is important in managing pregnancy-related complications and chronic disease, and in providing access to mental health and substance use disorder treatment, breastfeeding support, family planning services, and prescription drugs.
  • Several commenters agreed that extending the Medicaid postpartum coverage period will support the sustainability of the Medicaid program in Wisconsin by increasing utilization of preventive care and reducing the likelihood of inpatient hospital admissions and emergency room visits.
  • Some commenters observed that parental enrollment in Medicaid is associated with improved child health outcomes because children are more likely to have continued Medicaid enrollment and receive well-child visits and needed medical care.
  • One commenter observed that extending the Medicaid postpartum coverage period will help ensure continuous coverage for both postpartum person and baby, thereby improving care coordination for the postpartum person and baby and creating administrative efficiencies for the state at redetermination. 
  • One commenter at the public hearing observed that Indian Health Service (IHS) clinics are less likely to receive full reimbursement for postpartum visits that occur after 60 days, and that many new postpartum individuals miss their follow-up appointment at 6 weeks and have to reschedule after their Medicaid coverage ends at 60 days. The commenter also noted that these visits are often rescheduled to Primary Care Providers (PCPs) rather than to obstetrics and gynecology (OB/GYN) specialists.
  • One commenter observed that an extension to 90 days will support continuity of coverage by giving postpartum individuals more time to transition to other insurance programs or other forms of Medicaid.
  • Some commenters are concerned that if CMS approves a 90-day coverage waiver, a new precedent will be set for states across the U.S. in lieu of pursuing a full year of coverage. However, they also recognize that 30 days of extended coverage would increase completion of care plans and reduce the burden of uncompensated care for clinics across Wisconsin. In light of these realities, they neither support nor oppose the waiver.
  • One comment in opposition to the waiver opposed publicly-funded healthcare for pregnant and postpartum people for any duration. 
  • One comment opposed the waiver because the duration of coverage under the waiver does not align with the recent passage of the American Rescue Plan Act (ARPA) to provide 12-months of continuous Medicaid and CHIP coverage for pregnant and postpartum individuals.
  • One comment suggested that since DHS does not have authority to extend coverage to 12 months, DHS should do everything within its authority to support pregnant and postpartum people, such as incentivize managed care organizations to partner with community-based doulas by reimbursing them at a 1.25 rate, such as one state does with community health workers, or provide medically-tailored meals to people diagnosed with gestational diabetes, such as another state provides.
Details
Number Submission Date and Time Comment Method Attachment
1151 4/6/2022 15:34 I think that Medicaid Section 1115 demonstration project to extend the duration of postpartum coverage to the last day of the month 90 days after the last day of pregnancy should be passed. Email N/A
1152 4/6/2022 16:30 Are immigrant women covered under the BadgerCare Prenatal Program, specifically undocumented immigrants, included in this extension? Email N/A
1153 4/7/2022 13:27 I am writing you to inform you that, as a retired healthcare professional and RN Case Manager, in the best interest of providing care to mothers postpartum for 90 days should have been the norm from the beginning. I support extending healthcare coverage for Medicaid recipients postpartum to 90 days. Email N/A
1154 4/7/2022 13:28 I wholeheartedly support the extension of Medicaid benefits for postpartum women!! This is a no-brainer initiative to improve health outcomes for mother and baby in the critical postpartum time. As an RN, anything we can do to provide assistance for the most vulnerable of our citizens is obvious benefit not only to those receiving the assistance, but serves to create a healthier community overall. Children are fragile despite all the talk about 'resilience' - they are affected for life by events that happen from infancy and childhood.  Adverse childhood events or ACEs are well-known to healthcare providers and research and evidence-based practices demonstrate the need for support of parents and children to prevent ACEs and life-long health issues. Money spent for the well-being of the mother and infant will be major savings in the long term as the infant grows into a healthy adult. Email N/A
1155 4/7/2022 16:24 The postpartum period should be extended at least to the 90 day period for the monitoring of both mother and child for possible complications to the mother , ie. infection, post partum depression, and general well being, in the child for assessment of well being and any problems in bonding, failure to thrive, tongue tie, defects, etc. -Mother of 2 and an RN Email N/A
1156 4/7/2022 18:04 I believe this is the right thing to do. It’s important that the Mother and Child have this care. Email N/A
1157 4/8/2022 8:25 I am a certified nurse-midwife (CNM) at Sixteenth Street Community Healthcare Centers, and also a member of Wisconsin’s MMRT. I write in support of the proposal to extend Medicaid coverage from 60 to 90 days postpartum. Many of our patients have Medicaid only for pregnancy. This is problematic, because not infrequently health problems are identified that need ongoing care. Here are a few examples of patients who haven’t had appropriate care due to lack of coverage. 1. Women who require removal of gall bladder (cholecystectomy) and the timing of surgery is made based on when she will have insurance vs when would actually be ideal for her health 2. Women who need ongoing mental health care for postpartum depression, but are not able to access care. 3.Women who can’t get a postpartum tubal ligation because they give birth at a hospital that doesn’t allow it, and they have no access to it after their hospitalization 4. Women who have problems such as hypertension, diabetes, and thyroid problems identified in pregnancy, but can’t have them addressed postpartum because they run out of coverage. 5. Women who struggle with mental health and drug addiction problems, and lose access to therapy and medications postpartum. While 90 days won’t solve the problem completely, it is an improvement. Women will have healthier babies and pregnancies if they have access to care not just when they are pregnant. Email N/A
1158 4/8/2022 9:31 I am writing as an OBGYN physician in support of extension of Medicaid coverage for postpartum patients. As faculty at the Medical College of Wisconsin, I support legislation that extends healthcare access during the postpartum period and ensures continuity of care. We know that improving access to care for postpartum patients will improve health outcomes for women and children in the state of Wisconsin. Email N/A
1159 4/8/2022 9:32 As a newly retired nurse previously working in a MCO, I support extending Medicaid coverage for all but particularly for postpartum women. I participated in a team that reviewed high risk birth outcomes. We found that many women do not follow up due to a variety of social issues or if they are able to follow up, the limitations of coverage make check ups a once and done appointment. Extending this coverage would not only make follow up easier but it would also promote increased health outcomes for our underserved community. Increased health outcomes actually reduce costs as potential for undesired complications can be prevented. And as we all know, an ounce of prevention is worth a pound of cure. Email N/A
1160 4/8/2022 9:56 I am an OB GYN faculty in the department of Obstetrics and Gynecology and a member of Milwaukee's Fetal and Infant Mortality. I strongly support the extension of Medicaid coverage during the postpartum period. It is well accepted that one strategy to improve birth outcome in our community is to ensure individuals have access to quality reproductive health care, including postpartum care. This expansion of coverage is an important step toward a delivering more equitable health care services. Email N/A
1161 4/8/2022 10:05 I am writing to you as a practicing Maternal Fetal Medicine Specialist at the Medical College of Wisconsin and as a physician who takes care of high risk pregnant and postpartum patients.  Despite advances in obstetrical care, the United States still trails the developed world in its maternal mortality rate. While the rate of maternal mortality has fallen in most developed nations, it is rising here. In a 2015 study, the United States had the highest maternal mortality rate at 26.4 deaths for every 100,000 live births, followed by the United Kingdom at 9.2 deaths for every 100,000 live births. That translates into 2 to 3 women dying each day in the United States at a time that should be one of the happiest in their lives and the lives of their families. Currently, Medicaid coverage ends for many new mothers 60 days after giving birth, leaving them without insurance during a critical and vulnerable time. Data from the CDC indicate that about 33 percent of pregnancy-related deaths occur during the time between seven days to one year following childbirth, and greater than one-third of those deaths occur 43-365 days postpartum.  Closing the postpartum coverage gap will ensure that the 43 percent of pregnant people covered by Medicaid at the time of their child’s birth can receive treatment for the many physical and behavioral health issues that have been shown to cause maternal deaths in the postpartum period.  I urge you to extend Medicaid Coverage to one year postpartum in the state of Wisconsin. Email N/A
1162 4/8/2022 10:23 I am writing to you as a practicing Obstetrician Gynecologist at the Medical College of Wisconsin and as a physician who takes care of pregnant and postpartum patients. The United States is the richest nation in the world. We have here an opportunity to make a big difference in people’s lives with a small investment in pregnant women and new moms and babies that has the potential to lay the foundation for a healthy future for many children. I urge you to extend Medicaid Coverage to one year postpartum in the state of Wisconsin. Any increase, even to 90 days, will be valuable. Currently, Medicaid coverage ends for many new mothers 60 days after giving birth, leaving them without insurance during a critical and vulnerable time. Data from the CDC indicate that about 33 percent of pregnancy-related deaths occur during the time between seven days to one year following childbirth, and greater than one-third of those deaths occur 43-365 days postpartum. Closing the postpartum coverage gap will ensure that the 43 percent of pregnant people covered by Medicaid at the time of their child’s birth can receive treatment for the many physical and behavioral health issues that have been shown to cause maternal deaths in the postpartum period. Despite advances in obstetrical care, the United States still trails the developed world in its maternal mortality rate. While the rate of maternal mortality has fallen in most developed nations, it is rising here. In a 2015 study, the United States had the highest maternal mortality rate at 26.4 deaths for every 100,000 live births, followed by the United Kingdom at 9.2 deaths for every 100,000 live births. That translates into 2 to 3 women dying each day in the United States at a time that should be one of the happiest in their lives and the lives of their families. I am confident that the team responsible for making this positive change will have the welfare of this vulnerable population in mind when the final decision is made. Email N/A
1163 4/10/2022 11:22 No I do not think they should e given more time. Our parents worked for every thing they got. Why should the goverment pay them to have children. Email N/A
1164 4/11/2022 12:01 As a new mother who is on BadgerCare I would greatly appreciate the extension of the postpartum coverage from 60 to 90 days. Due to complications from my son's delivery that require special care for myself joint with the fact that many clinics and specialists are booked out well past 2 months' time - it would be medically necessary to have the additional time coverage so I can get the care I need. From physical therapy to meeting with an IBCLC - these are medical professionals that mothers need to have the time to schedule and see. 60 days often isn't enough time when available appointments are booked out by more than two months. Email N/A
1165 4/11/2022 12:58 I am writing in support of extension of Medicaid coverage for postpartum patients. As an obstetrician/gynecologist in Green Bay, I support legislation that extends healthcare access during the postpartum period and ensures continuity of care. We know that improving access to care for postpartum patients will improve health outcomes for women and children in the state of Wisconsin and save lives. Email N/A
1166 4/13/2022 9:10 I fully support extending Medicaid coverage for postpartum individuals from 60 to 90 days. Email N/A
1167 4/13/2022 11:54 I am a community-based doula, lactation counselor and student midwife serving Dane and Milwaukee counties. My work takes me intimately inside the lives of pregnant people and their families, forming highly personal bonds during their pregnancy to birth and often throughout the extended postpartum period. With more than a decade of providing direct care in the homes of clients, by their side in the clinic and hospital settings, my vantage point has greatly grown to adapt to the needs of the clients I serve, who represent Black/ African American and Indigenous women. On a national level, the rate of Black women in the United States who die from complications related to pregnancy or childbirth is two to three times higher than that of White women. Against that backdrop, our state of Wisconsin has the worst record in the nation for black infant mortality, and maternal mortality for Black mothers is five times higher than for White mothers; right here in our home state we are ground zero for this fight. In my practice, I have personally seen first-hand how a pregnancy related health complication can linger far beyond the current 60-day standard. I know that it is very likely that the 90-day extension will still miss people trying to access care- but without insurance coverage, will not. There is a misperception among many that pre-eclampsia is cured by inducing birth, and while we are thankful for the life-saving measure that this intervention is, it is well documented that the effects of postpartum preeclampsia may not present symptoms until 6 weeks after delivery and may not be fully resolved at 12 weeks. With gestational diabetes, even if the condition goes away after the baby is born, half of all women or birthing people will develop type 2 diabetes later. Perinatal mood disorders, which includes postpartum depression and postpartum anxiety disorders are already distressing for patients as they attempt to fulfill their roles as new parents, returns to their work or study. Without medical coverage that ensures that they get the treatment that their conditions require, a full 12 months is vital to avoid worsening their conditions and potentially destabilizing their families. My testimony here today is in support of this extension, with a call to action that includes establishing the 12-month postpartum marker as a goal for DHS and legislators in our state. Doing so positions Wisconsin as a responder to the crisis of death rates for Black African American residents by adding protection and potentially saving lives with a critical continuity of care. Newborn Wisconsinites deserve healthy, thriving families to go home to, we can do it. I urge the decision makers to submit this proposal to the federal government for immediate approval. Power to the Pregnant People! Email and Public Hearing N/A
1168 4/14/2022 12:17 As a perinatal professional for thirty years and a Research Fellow at the university who studies birth outcomes, I am a supporter for extending Medicaid Coverage. The extension of coverage will allow us to catch more mental health issues in new parents; encourage greater contraceptive use, which lengthens the interconception interval leading to better maternal health; and allow coverage for complications from labor and birth that are not discernible at the time of delivery. Some perineal injuries are not discernible until some healing has occurred, and then specialists are necessary to return the person to optimum health. Many times these people suffer because they no longer have coverage to go to a cosmetic surgeon for complex wound repairs or pelvic floor physical therapists to treat continence issues and pelvic pain. This can lead to lifelong suffering. As a Certified Sexuality Educator and researcher, this is one of my areas of expertise. If I can be on any help in offering expert testimony on any of these things, let me know. For now, just know I am a citizen who supports the extension of Medicaid coverage. Email N/A
1169 4/14/2022 17:15 I am writing as a Maternal Fetal Medicine physician in support of extension of Medicaid coverage for postpartum patients. As faculty at the Medical College of Wisconsin, I support legislation that extends healthcare access during the postpartum period and ensures continuity of care. We know that improving access to care for postpartum patients will improve health outcomes for women and children in the state of Wisconsin. Email N/A
1170 4/19/2022 11:43 I am writing to you today to support the waiver to increase Medicaid coverage to 90 days instead of 60 days. I work in my community of Dane County as a Licensed Midwife providing maternity care to 90% of Medicaid clients. Increasing Medicaid coverage to 90 days helps provide care during an increasingly vulnerable time in women's lives in the United States. According to the Center on Budget and Policy priorities, the rate at which women are dying during pregnancy or within 12 months of the last day of pregnancy has gone up in the past 25 years. Increasing Medicaid coverage to 90 days increases access to preventative services that address physical, mental, reproductive, and behavioral health needs and helps reduce disruption in postpartum care coverage. The American Journal of Obstetrics and Gynecology cited two studies in their July 2017 issue stating more than half of pregnancy-related deaths occur after delivery: 40% occur 1 to 42 days postpartum and 11.7% occur from 43 to 365 days postpartum; more than half of these deaths is considered preventable. Increasing Medicaid coverage to 90 days could decrease infant mortality and help reduce racial and ethnic infant death disparities. The 2018 American Journal of Public Health Issue stated that infant mortality fell by 50% more in expansion states (365-day expansion) than non-expansion states AND disparities in infant mortality rates along racial lines fell in those same expansion states. Some of the clients I have cared for have been increasingly overwhelmed by the physical and emotional changes after birth and are unable to keep their 6-week appointment before their coverage ends. Many of the clients I have cared for are still in need of pelvic floor support, lactation support, and mental health support well after 60 days. Medicaid expansion to 90 days allows the most vulnerable people in our community a larger window to stabilize and access care. Thank you for your work to expand Medicaid coverage. Email N/A
1171 4/19/2022 13:59 I am requesting that postpartum Medicaid coverage for eligible persons be extended 60-90 days. This extension was included in the Governor's budget, but has been removed by the Legislature. This extension is supported by professional health organizations and will save lives in WI and the US. More mothers are dying during the postpartum period of one year. In addition to other medical conditions, many women have new, chronic illnesses during and after pregnancy, as well as postpartum depression, anxiety, and substance use disorder that require ongoing access to medical care. This coverage is imperative to their health. Email N/A
1172 4/19/2022 14:12 I am writing to urge you to support extending Medicaid coverage for postpartum patients from 60 to 90 days. DHS is required to have public hearings (last hearing is Wed 4/20) and accept comments from the public to extend postpartum Medicaid. Extending postpartum Medicaid to 12 months is recommended by professional organizations. This will save lives and in WI and the US, more mothers are dying in the postpartum period of 1 year. Gov. Evers included it in his budget, but the Legislature removed this from their budget. Even women who do not experience complications during or after pregnancy or labor are likely to need medical support and possibly intervention after 60 days following labor. However, many women develop new chronic illnesses during and after pregnancy as well as postpartum depression, anxiety and substance use disorder that require ongoing access to medical care. If we want to make sure that the children of Wisconsin are growing up healthy, then we need to support the health and wellbeing of their mothers. Email N/A
1173 4/19/2022 15:16 The Medical College of Wisconsin (MCW) supports the Wisconsin Department of Health Service’s Wisconsin Postpartum Coverage 1115 Waiver to extend postpartum Medicaid coverage from 60 days to 90 days, as required by 2021 Wisconsin Act 58. Please find MCW’s memo in support of the waiver application, written by Amy Domeyer-Klenske, MD, Assistant Professor and Patient Safety and Quality Officer for MCW’s Department of Obstetrics and Gynecology. Email PDF
1174 4/19/2022 15:21 I am calling for the extension of Medicaid to 90 days postpartum. As a Mom of three girls, I will never forget the necessity of good caretaking after delivery. It is vital to mothers and children. Extending postpartum Medicaid to 12 months is recommended by professional organizations. This will save lives and in WI and the US. More mothers are dying in the postpartum period of 1 year. Many women have new chronic illnesses during and after pregnancy as well as postpartum depression, anxiety and substance use disorder that require ongoing access to medical care. Email N/A
1175 4/19/2022 16:24 Please extend Medicare coverage postpartum. It is a necessity and the only humane thing to do. Email N/A
1176 4/20/2022 10:19 I work for the community health center as the prenatal care coordinator. I was excited to hear about this new extended postpartum care. I work with primarily Native American women. We have a contract with a ob providers to come here and see women prenatally and postpartum which is a huge advantage that I know many tribal communities do not have. So we are thankful for that. But in my experience here I've found it, and I know overall everybody knows that postpartum care is currently fragmented. It's not ongoing it's not, you know, individualized for mom so definitely in our state we need to focus more on, you know, switching up postpartum care and this is a good step moving forward is to provide that additional 30 days. What I see in my clients is tasks stressed turns to baby, they're here for a well child checks at three weeks. Two weeks, and two months. And in the midst of all the other responsibilities they often forget about themselves and miss that postpartum exam. I was told, if they miss it with by, there's a certain timeline say six weeks or the 60 days, then the reimbursement is not as much for our facility to receive like a full reimbursement, and prenatal care up to delivery and then postpartum. So that's a financial burden for us here as a IHS, tribal facility. And also, due to increase responsibilities as moms, you know can forget. So the additional time I think would help them come back to be able to see that will be provider because once they're out of that timeline. Then they are often referred to as a primary care provider, not necessarily the op. So then the focus is more just on healthy adult versus that postpartum mom's needs. The additional time would increase this access to the OB provider who knows more about postpartum issues, which is important and it also would be more time to get them screened and referred for mental health services. I also see that as a need that we need to increase the amount of screening we do on moms. So, the increased time benefits. Mom, baby family and community. So I am in full support of the extended postpartum eligibility. Public Hearing N/A
1177 4/20/2022 10:22 I am just a member of the public but I also do work with the March of Dimes on a volunteer basis, I was Ambassador mom for that group, wanted to bring to light that myself. And because my child was born extremely prematurely. We were in the queue for the entire 60 day postpartum period. Once my child was born because we were, like I said, in patient in the nick you for that entire 60 days so the extension of this would mean so much, and give opportunities to moms, to really seek that care outside of that experience. I myself battle with mental health issues and would have loved to have someone say hey you know all baby stuff aside, how're you doing, and asked those important questions so I've been fortunate enough to speak at the Capitol with some representatives, and share my story a little bit further. But this would mean the world to so many Medicaid recipients that I feel even going through that process kind of get left behind. So I just wanted to thank you for considering this and continuing on postpartum care for a full year would make me what has given me the opportunity to not have to sacrifice so much and such vulnerable time and be able to care for myself and my family in a way that was much more well adjusted and prepared so thank you so much for bringing this to light and I think this is a great first step. Public Hearing N/A
1178 4/20/2022 10:25 I am the maternal child health manager at access community health centers, here in Madison, and we serve a lot of people who live right at or below the poverty level. And it is our mission to improve the health of people who don't have access to care, generally, and we see a lot of people postpartum that like as other people have mentioned that kind of fall by the wayside because they lose their insurance, and six weeks. This is such a vulnerable time for them with their new baby, and there's lots of things that can develop obviously after the six weeks, including anxiety and depression lactation issues. We know that breastfeeding is really important for both baby and mom's health. And we do provide lactation care in our clinic. But if they aren't covered then they won't you know be coming to the clinic or a lot of women don't come to their postpartum visit because they're afraid that it won't be covered. So it's hard to get people even to comment on other things that happen are pelvic floor dysfunction, other musculoskeletal issues which might require physical therapy and follow up. And then, women may not be ready to discuss contraception it six weeks, and it would be nice for them to have extra time to follow up on that issue as well. So those are just a few things that extra 30 days could help cover. As you know, the year postpartum is is a special vulnerable time for both mom and baby so that obviously would be even better but even 30 more days would make a huge significance and it would follow the typical maternity leave as well which is 90 days. And ideally, insurance should cover you know correspond with their maternal leave. Public Hearing N/A
1179 4/20/2022 10:28 I am from the Wisconsin Primary Care Association. We just want to share our extreme appreciation for your continued dedication for the full year of the postpartum coverage, as was indicated by another speaker this morning. I represent the Association of the 17 federally qualified health centers in the state, also known as community health center so they provide care for folks, regardless of their insurance status or ability to pay about 60% of them are Medicaid and released so we work with you all the time and appreciate the continued partnership. And we are excited about the momentum on extending coverage. We're a little bit torn as to whether this 30 day extension will stifle any of the momentum on the full year of coverage. But we know that DHS and Medicaid and the governor's office has been advocating for that full year of coverage all along and, and for folks regardless of their documentation status. We know that every little bit of additional care helps people in reaching their full potential. So, just want to thank you for that continued effort for the full year of coverage. Public Hearing N/A
1180 4/20/2022 10:59 I am writing today to share my thoughts on WI Act 58 which would extend Medicaid coverage to 90 days postpartum. Postpartum women are at risk for adverse pregnancy related outcomes through 1 year postpartum and it is necessary for WI along with all other states to offer coverage for the full year.I support any extension of the current 60 day coverage but I truly hope we do not stop at only 90 days. I would like to see coverage for the full year, as this would help to reduce our concerning rates of maternal morbidity and mortality. In WI in 2016-2017, 73% of pregnancy-related deaths occurred within the first year postpartum. Additionally mothers enrolled in Medicaid had a disproportionally higher rate of pregnancy related death during that same time frame. When the WI MMRT reviewed these deaths, 97% were deemed preventable. Some of the top contributing factors identified included access/financial issues and continuity of care. It that same document the team outlines recommendations for improve with a key recommendation to expand Medicaid coverage for “all postpartum people to one year post delivery.” Keeping mothers alive and healthy additionally benefits their newborns as well as their entire family. I would be happy to discuss further and provide data to support the year extension. However the CDC “Hear Her” campaign as well as our own WI DHS publications (e.g. www.dhs.wisconsin.gov/publications/p03226.pdf)  on the topic do an excellent job of covering the issue along with statements from many professional organizations like ACOG, AWHONN, AAP, AAFP, and SMFM. Please reach out at your convenience if you wish to discuss further. Please help our WI families by saving our mothers! Email N/A
1181 4/20/2022 11:25

I am the Co-Chair of the WI Maternal Mortality Review Team (MMRT) and Past Chair of WI American College of Obstetricians and Gynecologists. I also serve on the WI Perinatal Quality Collaborative. (WisPQC) In my experience and review of maternal morbidity and deaths, many women develop chronic or serious medical complications during or after pregnancy that require ongoing medical treatment. If a birthing person develops hypertension, diabetes, cardiomyopathy, depression, anxiety or other complications and loses quality insurance, they cannot access the treatment and medications necessary for health and potentially to save their life. Despite a declining birth rate, we have seen a rise in maternal deaths. We have also seen a rise in postpartum suicides and drug overdoses that could have been prevented! Maternal health impacts infant health and families. I fully support extension of postpartum Medicaid not only to the 90 days that was approved by the state legislator, but to 12 months postpartum!!! Access to coverage is critical to reducing pregnancy associated morbidity and mortality. Attached is the WI MMRT Mortality Report for 2016-2017 that was released this month. Key findings include:

  • 97% of pregnancy related deaths were preventable
  • 73% of pregnancy related deaths occurred in the postpartum period
  • During 2016-2017, Non-Hispanic Black, Non-Hispanic Asian, and Hispanic mother were overrepresented in pregnancy-related deaths
  • Mental Health Conditions contributed or likely contributed to 67% of the pregnancy-related deaths
  • 48% of all pregnancy-related deaths were due to overdose A KEY RECOMMENDATION IN OUR MMRT REPORT: Access/Financial
  • Policymakers should expand Medicaid eligibility for all postpartum people to one year post-delivery Extending postpartum coverage is rooted in clinical evidence.
  • ACOG guidance notes that the postpartum period should be an ongoing process “with services and support tailored to each woman’s individual needs.” This may include physical recovery from birth, an assessment of social and psychological well-being, chronic disease management, and initiation of contraception, among other services.
  • The CDC defines the postpartum period as extending through 12 months after the end of pregnancy, and data demonstrate that women who have recently given birth have health needs that continue throughout an infant’s first year of life.
  • Some of the most dangerous pregnancy-related complications –preeclampsia, blood clots, and heart problems such as cardiomyopathy – may not surface until weeks or months after delivery.

Extending postpartum coverage has wide support that continues to grow.

  • Among the physician community: the American Medical  Association, American Academy of Family Physicians, American Academy of Pediatrics, American College of Physicians, American College of Cardiology, American Osteopathic Association, American Psychiatric Association, and the Society for Maternal-Fetal Medicine.
  • Among other stakeholders: March of Dimes, Black Mamas Matter Alliance, American Hospital Association, Medicaid Health Plans of America, and America’s Health Insurance Plans.
Email PDF, PDF
1182 4/21/2022 14:25 Please grant the extension of the Medicaid coverage for birthing persons for 30 extra days after the initial 60 days post delivery to ensure safety for mothers and birthing persons. It is essential to save the lives of new mothers and parents. I have worked as an L&D nurse in Milwaukee for the last 10 years, and I cannot tell you how often women have to return to the hospital after they deliver for various reasons, including many emergencies. Truly, this should be extended to 12 months after birth, but we need EVERY DAY we can get. Do not hesitate, save lives. Email N/A
1183 4/21/2022 14:34 Why is our maternal mortality the highest in the world among developed countries? Because we do not support our mothers enough in the postpartum period. This is DIRECT ACTION to support our mothers in their most vulnerable time – physically, mentally, and financially. Every little bit counts. Supporting the mother will INDIRECTLY support the baby! 30 more days of coverage is one huge step closer to better maternal health care and maternal AND neonatal outcomes! Email N/A
1184 4/22/2022 8:29 Please find attached Nurse-Family Partnership’s comments on the Section 1115 postpartum coverage waiver. Please let me know if you have any questions. Email PDF
1185 4/22/2022 11:11 Please see attached for comments from the Wisconsin Association of Health Plans on the draft Section 1115 Waiver application to extend postpartum Medicaid coverage from 60 days to 90 days. Email PDF
1186 4/24/2022 16:23 I’m writing today in support of extending postpartum coverage for BadgerCare moms and babies beyond 60 days. While disappointing that our state leadership is not following the the American College of Obstetricians and Gynecologists’ recommendation to extend postpartum coverage to one year after birth, an additional 30 days is still an improvement. I hope to see my elected officials take further action to extend coverage, reflecting this constituent’s desire for our system as a whole to commit to improving health outcomes for the families of the 35% of births covered by BadgerCare. Email N/A
1187 4/26/2022 8:50 I am writing to express my support for extending postpartum Medicaid coverage from the current 60 days to 90 days postpartum. I am a nurse and public health professional and have worked with pregnant and postpartum people for over 30 years. I have seen firsthand how devastating the loss of Medicaid coverage at 60 days postpartum has been for families. In addition to pregnancy complications, so many chronic conditions are exacerbated by pregnancy, therefore access to healthcare beyond 60 days after birth is essential. Maternal mortality and severe morbidity rates are rising and alarming, and disproportionately affect women of color. Nearly three quarters of maternal deaths occur during the postpartum period and almost all of these deaths are preventable. Extending postpartum Medicaid to 90 days is an important step in preventing these deaths and reducing health disparities. It is my hope that Wisconsin will continue to work towards extending Medicaid for a full year postpartum. Email N/A
1188 4/26/2022 11:30 I am writing to express my firm support for extending postpartum Medicaid coverage from the current coverage period of 60 days to 90 days postpartum. As a member the Wisconsin Association for Perinatal Care and a perinatal professional in Wisconsin, I have a duty to my patients to advocate for change which removes barriers to high quality perinatal care. An astounding 73% of Wisconsin’s pregnancy-related deaths occurred up to one year postpartum, according to the most recent report from Wisconsin’s Maternal Mortality Review Team. Among deaths of birthing people enrolled in Medicaid at the time of their death, it is alarming and deeply troubling that 97% of these deaths were preventable. While we need to do much more to address this disparity, extending Medicaid coverage from 60 to 90 days postpartum is a step in the right direction for Wisconsin families. Email N/A
1189 4/26/2022 11:30 Same as comment 1189. Email N/A
1190 4/26/2022 12:32 Same as comment 1189. Email N/A
1191 4/26/2022 12:40 Same as comment 1189. Email N/A
1192 4/26/2022 13:15 Same as comment 1189. Email N/A
1193 4/26/2022 14:19 Same as comment 1189. Email N/A
1194 4/26/2022 14:42 Regarding the Wisconsin Department of Health Services regarding its request to the Centers for Medicare & Medicaid Services (CMS) to extend postpartum Medicaid coverage from 60 days to 90 days, as authorized by by 2021 Wisconsin Act 58: As the Co-founder and Executive Director of Moms Mental Health Initiative in Southeastern, WI, I strongly support extending postpartum Medicaid coverage from the current coverage period of 60 days to 90 days postpartum. Moms Mental Health Initiative is a grassroots peer led organization that helps pregnant and postpartum women navigate perinatal mood and anxiety disorders by sharing information, connecting them to resources and providing peer driven support. Since 2016, we have served over 600 perinatal women in Southeastern, WI who suffer from maternal mental health disorders such as postpartum depression. 1 in 5 women will experience one of these mental health disorders. 75% of those that screen at risk for a perinatal mental health disorder do not receive treatment. Suicide and overdose are the leading causes of death among perinatal women. Untreated maternal mental health disorders can cause long-term negative effects for the mother, baby and family. Furthermore, the monetary cost of not treating these conditions is $32,000 per mother-infant pair (adding up to $14 billion nationally) (mmhla.org). Many of these maternal deaths happen well past 60 days postpartum, and moms can suffer anytime from pregnancy to at least 1 year postpartum. We daily see the agony of these conditions which are treatable and deaths due to them are preventable. The obstacles to access the right help can be insurmountable but the addition of losing healthcare benefits after 60 days allows too many women to fall through the cracks. As maternal mental health advocates and as survivors of postpartum depression, anxiety and OCD, we at Moms Mental Health Initiative believe extending coverage will improve the life chances of children and save lives. Email N/A
1195 4/26/2022 15:28 Same as comment 1189. Email N/A
1196 4/26/2022 17:40 Please give every consideration to extending Medicaid coverage benefits from current period of 60 days to 90 days postpartum or longer. Email N/A
1197 4/26/2022 17:40 There are many ways this change will benefit postpartum women. Three diagnoses that come to mind include high blood pressure, depression, and substance use disorder. The striking physiologic changes that occur in the several weeks/months postpartum make these 3 diagnoses particularly important to monitor closely; without close follow up and treatment, severe morbidity and even mortality will increase. I also want to highlight another group of women who will benefit greatly from this change: These are women that need to catch up on treatment for health issues, treatment that she needed to postpone due to pregnancy. My job is as a Maternal Fetal Medicine physician, caring for women with medical complications during pregnancy. I often see pregnant women postpone important medical procedures, tests and treatments during pregnancy so as not to impose risk for her baby, but then miss out on needed health care because the coverage window postpartum is too short. Here are some examples from recent patients: One patient had a new lab finding of kidney disease during first prenatal visit. Kidney biopsy was needed to learn the underlying diagnosis, but she postponed the procedure so as not to put her baby at risk. Then, postpartum, was not able to get in for the procedure within 60 days, so the exact cause of her kidney disease remains unknown and treatment can’t be offered without that information.  Her kidney disease will progress without treatment and she may then require dialysis. Another patient with an abnormal cardiac valve couldn’t get treatment when it was diagnosed during her pregnancy, due to risk to her baby/pregnancy. Postpartum, she couldn’t make it to all of her many cardiology visits to be able to have it repaired. She was lost to follow up, and now, 2 years later, has critical heart valve disease due to lack of treatment.  If only she had more than just 2 months of coverage postpartume, she likely could have gotten this taken care of before it became critical. Another patient had precancerous findings on pap test in early pregnancy, could not get treatment during pregnancy---again, due to risk to baby, so she postponed her own care---and then unable to make it in time for definitive surgical treatment postpartum.  Her risk of progression to full blown cancer is high. Those first 60 days after bringing home a newborn baby are exhausting and shockingly busy. It is difficult to get out of the house for appointments or to be separated from baby for more than a few hours if breastfeeding. It does get easier with time, so extending benefits will make a large difference in the ability of these new mothers to find child care, get support from her network of family/friends and other resources to be able to get herself in for the care she needs. An extension of health care benefits beyond 60 days will provide a huge health benefit to these women. Their selfless actions of taking on personal health risk by delaying care during their pregnancies must not go unrecognized. Please give this important change every consideration, to benefit mothers and families across our state. Email N/A
1198 4/26/2022 19:34 Same as comment 1189. Email N/A
1199 4/8/2022 I wish to provide comment regarding the proposed change in postpartum coverage for women in with Medicaid coverage. I strongly support this change both as an obstetrician, but also an addictionologist. Women receive coverage for opiod treatment during pregnancy may find themselves cut off from their treatment options and medications upon completion of their Medicaid coverage after delivery. By extending the time limit, more women will have the opportunity to transition to other insurance programs or other forms of Medicaid. From my experience as a member of the Wisconsin Maternal Mortality Review Committee, I see many variables that put women at risk. The lack of continued healthcare due to lost of funding is a factor in many cases. I strongly urge approval and acceptance of this change in coverage plans for the state of Wisconsin. USPS Mail N/A
1200 4/27/2022 8:44 Same as comment 1189. Email N/A
1201 4/27/2022 9:21 I have been a registered nurse in Wisconsin for 3 years. This past year, I started a career in public health. I am a home visiting nurse at the City of Milwaukee Health Department in the Prenatal Care Coordination Program (PNCC). I am also a member of The Association of Women's Health, Obstetric and Neonatal Nurses (AWHONN). I am writing to express my support in DHS submitting a request to extend Medicaid coverage to 90 days postpartum. Ideally, I hope one day that coverage will extend to one year postpartum. As a registered nurse working with pregnant and postpartum people, I am a strong proponent that increasing access to care is fundamental in the effort to decrease maternal morbidity and mortality rates in our state. As part of the PNCC program, I am only able to provide care coordination to my clients until 60 days postpartum. I have frequently experienced that 60 days is a short period of time to finish coordinating care with my clients so that they can receive adequate follow up for postpartum complications as well as referrals to specialists, primary care, family planning, substance abuse services, and mental health services. Postpartum people would benefit from extended Medicaid coverage so that they can receive care for postpartum warning signs as well as postpartum depression, as these can occur up to one year after childbirth. According to the 2016-2017 Wisconsin Maternal Mortality Report, " Most pregnancy-associated deaths occurred post-partum in 2016-17 (75% overall, including pregnancy-related death), with approximately 73% of pregnancy-related death occurring postpartum." This report also concludes that 97% of these pregnancy-related deaths were preventable. One of the most important interventions to prevent maternal deaths is to increase access to care by expanding Medicaid eligibility to one year. 90 days is not long enough, but it is headed in the right direction. I express my support of DHS's request to extend Medicaid coverage in order to promote the health, safety and well-being of birthing people in Wisconsin. Fax N/A
1202 4/27/2022 17:22 Same as comment 1189. Email N/A
1203 4/28/2022 6:48 Same as comment 1189. Email N/A
1204 4/28/2022 8:47 Same as comment 1189. Email N/A
1205 4/28/2022 8:58 I am an OB/Gyn at the University of Wisconsin where I have been practicing for almost 10 years. I cannot thank you enough for taking this expansion into consideration. This expansion would be a tremendous benefit to the women of Wisconsin.The postpartum period can be a time of physical, medical, mental, and emotional challenge for most women. Many women experience complications in their pregnancy, such as preeclampsia and elevated blood pressures, that extend weeks and months into the postpartum period. As a provider, I have cared for many patients over the years who have lost their postpartum medicaid coverage while they are experiencing medical or emotional complications in the postpartum period. I cannot understate the helplessness and worry for these patients when the lose much of their access to care. Ultimately, this extension will aid women to obtain their necessary care which in turn will improve their health and wellness. This in turn, will impact not only the mother but the health of her baby and family. Email N/A
1206 4/28/2022 9:38 I am a clinical psychologist, deeply involved with maternal and infant mental health care for the past 20 years in the state of Wisconsin via direct mental health care provision, teaching and training other mental health providers, and in research related to mental health care access/needs for women suffering from postpartum depression. I am writing to express my strong support for extending postpartum Medicaid coverage from the current coverage period of 60 days to 90 days postpartum. This change is essential to allow women adequate time to heal and attend to their mental health – which in turn is related to the care and development of their infant. While much needs to be done yet to ensure access to health care for all birthing persons before, during and in the postpartum period - this legislation is a step toward creating a greater measure of much needed equity. Email N/A
1207 4/28/2022 10:56 Same as comment 1189. Email N/A
1208 4/28/2022 15:25 I am a local Wisconsin Obstetrics and Gynecology physician practicing at the University of Wisconsin. I am writing in strong support of expanding postpartum Medicaid coverage to 90 days. Despite the many advances we have made in medicine, maternal morbidity and mortality in the United States lags behind much of the world. Many of the health concerns which arise during pregnancy and postpartum period, such as depression, anxiety, diabetes, hypertension and heart disease worsen in the postpartum period. Unfortunately, 60 days is often not enough time to address these issues, leaving these patients to forgo care for these life altering and sometimes life threatening conditions. For instance, I had a personal patient who developed postpartum depression and postpartum heart failure. Given long wait times for new patients, she was only able to be seen twice with cardiology and once in psychiatry before her insurance coverage ended. These initial consultation visits did not even begin to fully evaluate let alone treat her complex medical conditions. She is now no longer able to afford the care she needs, putting her at increased risk of heart attacks, strokes, heart failure, suicidal ideation, and early death, affecting not only her life but her ability to care for her family. This is sadly only one of many cases in which maternal and truly family health has been sacrificed due to a lack of insurance coverage. I would like to sincerely thank you again for taking the time to address this critical shortcoming in our medical care. I am hopeful that this is the first step towards the goal of expanding coverage to 1 year postpartum as is recommended by both the American College of Obstetrics and Gynecology and the American Medical Association.   N/A
1209 4/28/2022 22:38 Same as comment 1189.   N/A
1210 4/29/2022 8:31 See attached statement from WPHCA. Email PDF
1211 4/29/2022 15:50 See AHI Comments regarding the Section 1115 Postpartum Coverage Waiver Email PDF
1212 5/2/2022 8:26 Same as comment 1189. Email N/A
1213 5/2/2022 8:52 I am writing to contribute to the public comments regarding the expansion of coverage for maternal health. I’ve provided care to more than 10 thousand families and I know that adding support services, such as traditional health workers, doulas and postpartum care and other home visitors, and access to medical care as needed, is a critical component to fill the gaps in our care system. I have countless stories of lives saved and dollars saved and have worked with families whose state insurance (Netherlands) cover their care even when abroad in the US. It’s estimated that in one year alone, 32 billion dollars were spent on preventable complications. Extending access to care into the postpartum time is not only the moral solution, but it’s the fiscally responsible one as well. Email N/A
1214 5/3/2022 15:25 Please find attached Children’s Wisconsin’s comment letter in support of the 1115 Waiver requesting approval for extending postpartum coverage. Email PDF
1215 5/3/2022 15:35 Same as comment 1189.   N/A
1216 5/4/2022 13:23 Attached is the March of Dimes of Wisconsin comment on the Postpartum Coverage 1115 waiver. Email PDF
1217 5/5/2022 7:06 Same as comment 1189. Email N/A
1218 5/5/2022 20:48 Attached is the comment from the American College of Obstetricians and Gynecologists - Wisconsin Email PDF
1219 5/6/2022 8:59 Attached is the comment from The Wisconsin Alliance for Women's Health Email PDF
1220 5/6/2022 8:59 Attached is the comment from the American Heart Association Email PDF
1221 5/6/2022 10:20 Wisconsin faces a maternal health crisis. Maternal morbidity– when birthing individuals are admitted to the ICU, experience a ruptured uterus, a transfusion, or an unplanned hysterectomy– is consistently higher in the state than the national average. And, the pregnancy related mortality ratio for Black Wisconsinites is 5x that for non-Hispanic White residents. Currently, BadgerCare covers prenatal and birthing services for pregnant individuals with incomes up to 306% of the Federal Poverty Level (FPL). However, just sixty days after the end of pregnancy, individuals earning more than 100% FPL (a difference of more than $47,000/year for a family of three in 2022) lose coverage. According to the Assistant Secretary for Planning and Evaluation roughly 13,000 individuals in Wisconsin fall into this gap every year. Losing coverage– even if just for a short period of time– puts the lives of postpartum people in danger. 73% of pregnancy-related deaths in Wisconsin occur during the postpartum period. Serious conditions such as postpartum hemorrhage can occur up to 12 weeks after birth and postpartum depression can persist for a year after birth and beyond. The American Rescue Plan Act of 2021 gave states the option to extend coverage for 12 months postpartum through a state plan amendment– with a 100 percent federal match. And Wisconsin’s Maternal Mortality Review Commission recommended that policymakers adopt this option. However, instead of taking the necessary (and fully funded) step to support the families of Wisconsin, the state legislature opted to extend postpartum coverage by only thirty days. This extension would be wholly insufficient to support new parents in Wisconsin. Over half of the pregnancy-related deaths in Wisconsin were related to mental health conditions– which, as noted above, most certainly persist beyond 90 days and require sustained treatment. While we recognize that this ridiculous 30 day timeline was mandated by the legislature, we urge the Department to do everything within its authority to support pregnant and postpartum people. For example, the state could incentivize the managed care organizations to partner with community-based doulas by reimbursing them at a 1.25 rate as Michigan does with community health workers. The state could also look to New Jersey for inspiration, where the state has requested expenditure authority to provide medically-tailored meals to people diagnosed with gestational diabetes. Email N/A
1222 5/6/2022 15:52 Attached is the comment from Planned Parenthood of Wisconsin Email PDF
1223 5/6/2022 16:20 Attached is the comment from Wisconsin Catholic Conference Email PDF
1224 5/6/2022 16:48 Attached is the comment from UW Health Email PDF

 

Last revised August 23, 2022