Iowa Medicaid pregnancy and infant income limits from IA-25-0019 (April 1, 2025) #10461

Iowa SPA IA-25-0019 changed two Iowa Medicaid income standards from April 1, 2025, and main has neither change. #10241 found this while dating Iowa's postpartum extension and left it out of scope.

What the sources say

• Pregnancy. IA-25-0019 reduces "the income standard for the pregnant women eligibility group from 375% to 215% of the FPL" (page 5). The Pregnant Women group page lists "FPL 215.00%", effective 4/1/2025 (page 14). Iowa Code 249A.3(1)(l)(2), as amended by SF 2251 (2024 Acts, ch 1141), also says 215% (Iowa Code 249A.3). With the 5 percentage point disregard, the stored limit would be 2.20.
• Infants. The SPA reduces the standard "for infants in the infants and children under age 19 group from 375% to 300% of the FPL" (page 5). The infant standard on page 10 is "FPL 300.00%", effective 4/1/2025. That would be 3.05.
• Date. IA-25-0018 (page 2) moved the effective date of the earlier SPAs IA-25-0001 and IA-25-0003 "from January 01, 2025, to April 01, 2025". IA-25-0019 is effective April 1, 2025 (page 2). The CHIP companions IA-25-0020 and IA-25-0021 also took effect April 1, 2025.

What main has

• gov/hhs/medicaid/eligibility/categories/pregnant/income_limit.yaml: IA: 2018-01-01: 3.80 (375% plus 5), unchanged.
• gov/hhs/medicaid/eligibility/categories/infant/income_limit.yaml: IA: 2018-01-01: 3.80, then 2025-01-01: 2.20.
  • Commit af018df (2026-08-03, which closed Iowa infant and Nevada pregnant Medicaid limits outdated vs 2025 SPA levels #9183) set that value from the SF 2251 fiscal note.
  • 2.20 is the pregnancy value, and 2025-01-01 is the date that IA-25-0018 replaced.
• gov/hhs/chip/child/income_limit.yaml: IA: 2018-01-01: 3.07 (302% plus 5), which matches the separate CHIP top of 302%.

Open question for the infant value

The sources split the infant band among three programs:

• Iowa Code 249A.3(1)(l)(1) covers "an infant whose family income is not more than two hundred fifteen percent of the federal poverty level".
• The SF 2251 fiscal note expects "approximately 1,100 infants in families with income between 215.0% and 302.0% of the FPL" to move from Medicaid to Hawki.
• CMS describes a three-way split for infants under 1:
  • IA-25-0021 "reduces the income level from 375 to 300 percent FPL in the Medicaid expansion program for children ages 0 to 1" and covers 300 to 302% in separate CHIP (page 2).
  • IA-25-0020 says the "Medicaid expansion program provides coverage for children ages 0 to 1 from 240 to 300 percent of the FPL" (page 2).

So Title XXI-funded Medicaid expansion covers infants in Medicaid up to 300%, and only 300 to 302% is separate CHIP.

The fix needs to decide which reading the infant parameter follows. The Medicaid infant limit should equal 3.05 if it includes Title XXI-funded Medicaid expansion, as the 300% in IA-25-0019 does. It should equal 2.20 if it follows the state statute's 215%. If the parameter keeps 2.20, infants from 215% to 302% fall to the CHIP child limit (3.07), which matches the fiscal note's expected shift to Hawki. The state statute and the approved state plan disagree, so this may also need a source-conflict register entry.

Proposed change

• Pregnancy: IA: 2025-04-01: 2.20, citing IA-25-0019 pages 5 and 14 and Iowa Code 249A.3(1)(l)(2).
• Infants: move the 2025 value's date to 2025-04-01, and set the value per the open question above (3.05 under the SPA reading). Cite IA-25-0019 page 10, plus IA-25-0020 and IA-25-0021 page 2.
• Tests: is_pregnant_for_medicaid.yaml and is_infant_for_medicaid.yaml cases at the new limits in annual 2026, and annual 2025 cases showing the old limits (the variables read January 1 values).

Related

• Date 12-month Medicaid postpartum coverage from each state's approval #10241 (Iowa postpartum extension from 2025-04-01; its Iowa tests use an income level of 1, so they do not depend on this).
• Iowa infant and Nevada pregnant Medicaid limits outdated vs 2025 SPA levels #9183 (closed): the earlier Iowa infant update.
• State Medicaid/CHIP effective FPL limits stale vs post-2023 SPAs (AK, IA, ND, NV, WA) TheAxiomFoundation/rulespec-us#1185: stale state Medicaid and CHIP limits, including Iowa.