Add California County Children's Health Initiative Program (CCHIP) - #9434

Summary

Implements California's County Children's Health Initiative Program (CCHIP), the separate CHIP population for children under 19 in San Francisco, San Mateo, and Santa Clara counties with household income above the Medi-Cal child limit (266% FPL) and at or below 322% FPL.

Testing CCHIP against Medi-Cal surfaced three California Medi-Cal rules the model encoded differently from DHCS guidance, so this PR also corrects them:

• Medi-Cal household size counts the unborn children of every pregnant member of the applicant's MAGI household (DHCS ACWDL 20-10), not only the applicant's own pregnancy.
• California's child and pregnancy Medi-Cal income ceilings are inclusive, so income exactly at 266% FPL (children) or 213% FPL (pregnancy) stays in Medi-Cal instead of moving to CCHIP or the Medi-Cal Access Program.
• California's FCEP population is the Medi-Cal Access Program (MCAP), which excludes applicants with other health coverage (WIC §§ 15833–15834). The CHIP disqualifying-coverage list now applies to FCEP in California.

Closes #8522

Regulatory authority

CCHIP

• Cal. Welf. & Inst. Code § 15853(a)(1): Title XXI immigration rules; family income "at or below 317 percent of the federal poverty level" before MAGI conversion; child "does not qualify for the optional targeted low-income children group or the Access program" and "does not qualify for Medi-Cal with no share of cost"
• Cal. Welf. & Inst. Code § 15850.1(d): "'Child' means a person under 19 years of age"
• Cal. Welf. & Inst. Code § 15850.5(c): no CCHIP applicants beyond the counties participating on March 23, 2010; § 15854.5: $0 subscriber contributions from July 1, 2022
• California Title XXI CHIP State Plan, SPA CA-24-0012 (approved April 17, 2025), Section 1.1 narrative, Population 1 CCHIP: above 261 up to and including 317 percent FPL; Section 2 (age 0 up to 19, three counties, p. 23); Section 4.1-LR (CHIPRA 214 lawfully residing option elected for children, pp. 85–86); Section 4.4.1 (uninsured, p. 92); Section 8.2 (premiums $0 since July 1, 2022; copays not applicable, p. 123)
• CMS approval of SPA 20 (CA-17-0045): current CCHIP band effective January 1, 2014
• DHCS program descriptions by FPL (CCHIP 266 to 322% FPL)
• Santa Clara County Medi-Cal handbook, CCHIP
• CMS SHO #12-002: DACA recipients are not lawfully residing for Medicaid and CHIP; CMS SHO #26-001: the October 1, 2026 funding limits leave CHIPRA 214 coverage unchanged

Medi-Cal interactions

• Cal. Welf. & Inst. Code § 14005.26: optional targeted low-income children "up to and including" the threshold, set at 261% FPL before MAGI conversion by subdivision (b)
• 42 CFR 435.118(b) and 42 CFR 435.116(b): children and pregnant women "at or below" the state income standard
• DHCS Program Income Eligibility Comparison, 2025: OTLICP "up to 266% FPL"; CCHIP and MCAP "above 266%, up to and including 322% FPL"; 266% FPL for three people is $70,889
• DHCS ACWDL 20-10, MAGI Medi-Cal household compositions: the unborn children of a pregnant tax filer, spouse, or tax dependent belong to the household composition; DHCS MAGI household size flow chart, step 8; 42 CFR 435.603(b) state option
• Cal. Welf. & Inst. Code § 15832(a)(1)(B): MCAP income "above 208 percent ... but does not exceed 317 percent" before MAGI conversion; § 15833: ineligible if eligible for no-cost Medi-Cal or Medicare; § 15834: ineligible for services covered through private coverage; 10 CCR § 2699.200(b)(1)(F)–(G)

Program overview

• Administration: counties on behalf of DHCS; applicants are screened for no-cost Medi-Cal through CalHEERS
• Funding: Title XXI separate CHIP
• Rules: one rule set for all three counties (state plan Population 1); only the delivering managed care plan differs by county

CCHIP eligibility

California Medi-Cal changes

Benefit

Eligible children take the new CHILD_CCHIP branch of chip_category. Everything downstream (is_chip_eligible, chip_enrolled, per_capita_chip, chip, chip_federal_share, is_aca_ptc_eligible) keys off chip_category != NONE and is unchanged. per_capita_chip already uses California's MACPAC separate-CHIP spending and enrollment, which include CCHIP.

CHILD_CCHIP is appended after NONE in the enum so the existing indices, which 74 analytics-coverage tests assert numerically, do not shift. In select it sits after CHILD; the two never overlap because California's statewide child CHIP limit is -.inf.

Not modeled (by design)

Files

parameters/gov/states/ca/dhcs/cchip/{income_limit,counties}.yaml
variables/gov/states/ca/dhcs/cchip/ca_cchip_eligible.py
variables/gov/states/ca/dhcs/medi_cal/ca_medicaid_household_pregnancies.py
variables/gov/hhs/chip/chip_category.py                       (CHILD_CCHIP branch)
variables/gov/hhs/chip/is_chip_fcep_eligible_person.py        (California coverage exclusion)
variables/gov/hhs/medicaid/income/medicaid_household_size.py  (California pregnancy counting)
variables/gov/hhs/medicaid/eligibility/categories/{infant,young_child,older_child,pregnant}/*_fc.py
variables/gov/hhs/medicaid/eligibility/categories/older_child/is_older_child_for_medicaid.py
tests/policy/baseline/gov/states/ca/dhcs/cchip/{ca_cchip_eligible,integration,interactions}.yaml
tests/policy/baseline/gov/states/ca/dhcs/medi_cal/ca_medicaid_household_pregnancies.yaml
tests/policy/baseline/gov/states/ca/dhcs/mixed_households.yaml
tests/policy/baseline/gov/hhs/chip/{chip_category,is_chip_eligible_fcep}.yaml
tests/policy/baseline/gov/hhs/medicaid/eligibility/categories/{is_young_child,is_older_child,is_pregnant}_for_medicaid.yaml
tests/policy/baseline/gov/hhs/medicaid/income/medicaid_income_level.yaml
programs.yaml, changelog.d/ca-cchip.added.md

Test plan

• 17 unit cases for ca_cchip_eligible (each county, Los Angeles, unknown county, 322% boundary both sides, Medi-Cal eligible, age 18/19, undocumented, DACA, LPR, TPS, ESI, employer coverage available, out of state)
• 10 integration cases: married couple with an 8-year-old at 300% FPL in each county gets CHILD_CCHIP and chip of 13,119.89 with ACA PTC eligibility off for the child; Los Angeles, above 322%, below 266% (routes to Medi-Cal), pregnant spouse (FCEP) plus child (now Medi-Cal because the household counts the unborn child), child with ESI, child with employer coverage available, DACA child
• 11 interaction cases: pregnant-parent households keep Medi-Cal, CARE and WIC; children at $70,889 vs $70,889.01 (the 2025 three-person 266% line) split between Medi-Cal and CCHIP for ages 0, 3 and 8; MCAP exclusion for a pregnant teenager and a pregnant parent with ESI
• 8 household pregnancy cases (twins, pregnant dependent, several pregnant members, separately filing spouses, unrelated roommate, externally claimed dependent, non-California control) and 2 mixed-state vectorization cases
• 6 new California FCEP cases (uninsured, ESI, direct purchase, reported Medi-Cal, employer offer without enrollment, Texas control); child and pregnancy category boundary tests updated to the inclusive California ceiling
• The YAML suite has not been run locally; CI is the check
• CI passes

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