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…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>
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>
This was referenced Oct 26, 2026
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October 27, 2026 00:12
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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_coverageto both pregnancy pathways in every state.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_coveragelose 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 aggregatehas_health_coverage_other_than_chipinput. 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_esiorhas_health_coverage_other_than_chipfor a pregnant person outside California now get no CHIP pregnancy coverage for that person.Tests
is_chip_eligible_pregnant.yamlCase 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.yamlCase 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 frommain.tests/policy/baseline/partners/**) have none and are unaffected.Overlap with other open work
is_chip_eligible_standard_pregnant_person.pytoo. The two edits touch different lines andgit merge-filemerges them cleanly in either order. Once both merge, the coverage test also applies through the postpartum period, as 1397ll(d)(2) intends.is_chip_eligible_pregnant.yamlbecause Extend standard pregnancy CHIP through the postpartum period #10363 and Correct CHIP and Medicaid pregnancy income limits and effective dates #10365 both append cases tois_chip_eligible_standard_pregnant_person.yaml. Correct CHIP and Medicaid pregnancy income limits and effective dates #10365 also appends tois_chip_eligible_fcep.yaml; that file merges cleanly with this PR in either order.Not modeled
Not changed here
Test plan
make format(ruff)changelog.d/axiom: TheAxiomFoundation/rulespec-us#1929 queued
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