California MCAP: keep applicants whose private plan lacks maternity benefits or has a maternity deductible above $500 #10477

Problem

California's Medi-Cal Access Program (MCAP), its CHIP unborn-child population above the Medi-Cal pregnancy limit, excludes applicants with private maternity coverage but keeps those whose private plan lacks maternity benefits or carries a large maternity cost-sharing amount. The former AIM rule, 10 CCR 2699.200(b)(1)(G), reads:

(G) Not be covered for maternity benefits in a private insurance arrangement as of the application date. A pregnant woman in a private insurance arrangement with a separate maternity only deductible or copayment greater than $500 shall be deemed not covered for maternity benefits for purposes of determining eligibility.

is_chip_fcep_eligible_person excludes any applicant with coverage in gov.hhs.chip.disqualifying_health_coverage, including a Californian whose employer plan has no maternity benefits or a maternity-only deductible above $500.

Proposed fix

• Confirm the current MCAP rule (Welf. & Inst. Code 15833-15834 and current DHCS MCAP guidance), since 10 CCR 2699.200 is the former MRMIB rule.
• If it still applies, add inputs for a private plan's maternity coverage and maternity-only cost sharing, and let a California applicant through when the plan lacks maternity benefits or the cost sharing exceeds the threshold.

Related

• Apply the CHIP no-other-coverage test to pregnancy pathways in every state #10371 (lists this under "Not modeled"), CHIP pregnancy pathways skip the no-other-coverage test outside California #10368.
• Encode the CHIP no-other-coverage requirement for pregnant women and unborn children (42 USC 1397ll(d)(2)(C); 42 CFR 457.310(b)(2)) (PE-US PR 10371) TheAxiomFoundation/rulespec-us#1929, interpretation 5.