March 22, 2021

Karen Kimsey

Agency Director

Virginia Department of Medical Assistance Services

600 E. Broad St.

Richmond, VA 23219

RE: Family Access to Medical Insurance Security (FAMIS) MOMS and FAMIS Select Section 1115 Demonstration Amendment

Dear Director Kimsey,

NAMI Virginia, the state chapter of the National Alliance on Mental Illness, appreciates the opportunity to comment on Virginia’s FAMIS MOMS and FAMIS Select Section 1115 Demonstration Amendment that would extend postpartum Medicaid coverage for 10 additional months after the end of a pregnancy. NAMI is the nation’s largest grassroots mental health organization dedicated to building better lives for the millions of Americans affected by mental illness. 

Each year, mental illness impacts one in five Virginians.[i] NAMI Virginia uniquely recognizes the important role Medicaid plays in helping Virginians with mental illness successfully manage their condition and get on a path of recovery, including supporting the mental health needs of postpartum mothers.  As such, NAMI Virginia supports this demonstration amendment and urges its submission by the VA Department of Medical Assistance Services to the federal Department of Health and Human Services (HHS) for approval.

Medicaid is Critical for Addressing Mental Health Needs of Postpartum Mothers

The days and weeks following birth are a vital period for a woman and her infant, setting the stage for long-term health and well-being.  In normal times, one in five women are affected by anxiety, depression, and other maternal mental health conditions during pregnancy or the year following pregnancy. These illnesses are the most common complication of pregnancy and childbirth, impacting 800,000 women in the United States each year.[ii] Additionally, women are more likely to develop depression during the first year following childbirth than at any point in their lives,[iii] impacting at least one in nine new mothers.[iv]  Likewise, women with substance use disorder are also at greater odds of experiencing a relapse and overdose 7-12 months postpartum.[v]

Yet national figures show that untreated perinatal mental health conditions are often underdiagnosed and untreated.  Less than 20 percent of women get treated for such conditions postpartum[vi] even when they do screen positive.[vii]  Unfortunately, when left untreated, mental health conditions are the second leading cause of pregnancy-related death that occur within 43 days to one year after the end of pregnancy.[viii] 

In Virginia, Medicaid covers more than a third of all births.[ix] Pregnant women are eligible for Medicaid coverage up to 60 days postpartum, at which time they must transition to other insurance or become uninsured. While some Virginians can successfully transition to other sources of coverage like the state’s Medicaid expansion program, some may struggle to find an alternative, and many are left in the untenable position of being uninsured shortly after a major medical event.[x]^,[xi]  Others may successfully find other forms of coverage but might need to switch providers and have their continuity of care disrupted as a result.

This abrupt cutoff can thrust new mothers into the ranks of the uninsured or underinsured, limiting their access to essential services and medications. When new mothers go off and on coverage – called “churn” – their mental and physical health suffers. Specifically, when individuals with mental health conditions “churn” they are less likely to receive outpatient mental health services.[xii]  This experience is sadly not unique: it is estimated that more than half of women with Medicaid coverage at the time of delivery experience at least one month of being uninsured in the six months after delivery.[xiii]

Virginia’s proposal would reduce the likelihood of new mothers becoming uninsured and without care by extending Medicaid postpartum coverage for women covered under the existing FAMIS MOMS and FAMIS Select demonstration for 10 additional months after the end of the pregnancy for women with incomes between 138 percent and 205 percent FPL. This would mean a total of 12 months’ worth of coverage, impacting 910 to 1,590 women throughout the demonstration years. This proposal, coupled with Virginia’s Medicaid expansion in January 2019 for non-elderly adults with incomes at or below 138 percent FPL, means more continuous coverage options that will allow Virginian women greater access to necessary care for conditions like mental illness.

For all these reasons, NAMI Virginia supports the mental health and wellness of new mothers and is grateful that Virginia is electing to expand access to this vital source of coverage.  We urge the state to move forward with this plan and submit to HHS for approval. Thank you for the opportunity to provide comments.

Sincerely,

Kathy Harkey, MAPP, BSP, BSMDS

Executive Director

NAMI Virginia