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Apply the CHIP no-other-coverage test to pregnancy pathways in every state - #10371

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hua7450:chip-pregnant-coverage-test
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hua7450 wants to merge 4 commits into
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hua7450:chip-pregnant-coverage-test

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@hua7450 hua7450 commented Oct 21, 2026 •

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Closes #10368

What and why

CHIP covers only people without other health coverage. PolicyEngine applied that test to children in every state but to pregnant people only in California's FCEP (MCAP) pathway. This PR applies has_chip_disqualifying_health_coverage to both pregnancy pathways in every state.

Pathway Before After Source
Standard pregnancy option (CO, KY, MO, NJ, RI, VA, WV) No coverage test Excluded if covered 42 U.S.C. 1397ll(d)(2)(C): a targeted low-income pregnant woman meets 1397jj(b)(1)(C) "in the same manner as a child"
Unborn-child (FCEP) option, 24 jurisdictions besides CA from 2026 (23 before DC's option started in October 2025) No coverage test Excluded if covered 42 CFR 457.10 ("child" includes "the period from conception to birth"); 42 CFR 457.310(b)(2)
FCEP in California (MCAP) Excluded if covered Unchanged WIC §§ 15833-15834

Whose coverage counts for the unborn child. The 2002 unborn-child final rule (67 FR 61956) says the other eligibility criteria "pertain to the unborn child" and that the option is meant to reach people "who are currently uninsured". States test the mother's coverage. For example, Missouri's Show-Me Healthy Babies requires that "The pregnant woman must be uninsured" (MO DSS memo IM-110). PolicyEngine has no unborn-child entity, so the pregnant person's coverage stands in, as the California branch already assumed.

Microsimulation effect

Pregnant people with any coverage in gov.hhs.chip.disqualifying_health_coverage lose CHIP pregnancy eligibility outside California. That list covers employer, Medicaid, Medicare, Marketplace and other direct-purchase coverage, TRICARE, VA, CHAMPVA and other means-tested coverage, plus the aggregate has_health_coverage_other_than_chip input. CHIP enrollment and spending on pregnant people fall in the 27 affected jurisdictions (26 in 2024 and 2025). The population effect has not been measured.

API callers who send has_esi or has_health_coverage_other_than_chip for a pregnant person outside California now get no CHIP pregnancy coverage for that person.

Tests

  • is_chip_eligible_pregnant.yaml Case 5: a pregnant New Jersey resident at 200% FPL with employer coverage. New Jersey has only the standard option, so this case isolates it.
  • is_chip_eligible_fcep.yaml: the case "The California MCAP insurance exclusion does not reach Texas FCEP" asserted the old California-only behavior. It now asserts that Texas FCEP excludes the insured applicant, at 205% FPL (above Texas Medicaid's 203% pregnancy limit, within the 207% FCEP limit). The comment above the California cases now says the list applies in every state.
  • ca/dhcs/medi_cal/mixed_households.yaml Case 2, renamed "CHIP no-other-coverage exclusion is applied per person in a mixed-state population": the Texan is now uninsured at 205% FPL and keeps FCEP coverage, so the vector still holds an insured Californian (excluded), an uninsured Texan and an uninsured Californian (both covered). Expected values are unchanged from main.
  • A static scan of the YAML suite found no other case with an insured pregnant person outside California. Partner contract tests (tests/policy/baseline/partners/**) have none and are unaffected.

Overlap with other open work

Not modeled

Not changed here

Test plan

  • make format (ruff)
  • Changelog fragment in changelog.d/
  • Local review: statute, regulation and state manuals checked; changed expectations checked by hand
  • CI passes (tests were not run locally)

axiom: TheAxiomFoundation/rulespec-us#1929 queued

🤖 Generated with Claude Code

…state

Standard pregnancy CHIP now excludes pregnant people with disqualifying
health coverage (42 USC 1397ll(d)(2)(C)), and the unborn-child (FCEP)
option applies the exclusion in every state rather than only in
California (42 CFR 457.10, 457.310(b)(2)).

Fixes PolicyEngine#10368

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
hua7450 and others added 2 commits October 26, 2026 16:41
The FCEP and mixed-household tests no longer call the exclusion
California-only. The Texas households sit above Texas Medicaid's pregnancy
limit, and the mixed case again has an eligible Texan.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>

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CHIP pregnancy pathways skip the no-other-coverage test outside California

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