Fix CA Medi-Cal immigration eligibility for DACA/TPS in 2026

[hua7450]

Summary

The implementation of is_ca_medicaid_immigration_status_eligible has two issues:

1. Pre-2026: The variable doesn't filter by immigration status - it returns True for everyone in CA meeting age requirements, including citizens/LPRs who should use federal Medicaid instead
2. 2026+: DACA/TPS holders incorrectly lose eligibility because the enrollment freeze logic only grants continuous coverage to UNDOCUMENTED status

Regulatory Authority

• California Welfare and Institutions Code Section 14007.8
• WCLP - Medi-Cal Immigration Changes Practice Tip (Jan 2026)

Current Behavior

Pre-2026

# Old code: returns True for EVERYONE in CA within age range
return standard_eligible  # No immigration status check!

Person	Old Output	Should Be
DACA, age 30, 2024	✅ True	✅ True
CITIZEN, age 30, 2024	✅ True	❌ False (use federal)

2026+ (enrollment freeze)

# Old code: only UNDOCUMENTED gets continuous coverage
continuous_coverage = receives_medicaid & undocumented
return standard_eligible | continuous_coverage

Person	Old Output	Should Be
DACA, age 50, 2026	❌ False	✅ True (not affected by freeze)
UNDOCUMENTED, age 50, 2026 (has prior)	✅ True	✅ True

January 2026 Enrollment Freeze

Per WCLP Practice Tip:

Affected by freeze:

• Adults with no immigration status (undocumented)
• Adults with unverified status
• Adults with non-immigrant visas (student, work, tourist)

NOT affected by freeze:

"All immigrants with other statuses are not affected by this change! This includes: green card holders and applicants (regardless of the five-year waiting period); DACA recipients; refugees; asylees; Cuban/Haitian entrants; Violence Against Women Act (VAWA) petitioners; non-VAWA battered immigrant categories; parolees; U visa applicants and holders; T visa applicants and holders; Citizens of Micronesia, the Marshall Islands, and Palau (COFA); people Permanently Residing in the U.S. Under Color Of Law (PRUCOL); and more."

Expected Behavior

Status	2019 (age 30)	2024 (age 30)	2026 (age 50)
CITIZEN	❌ (use federal)	❌ (use federal)	❌ (use federal)
LPR	❌ (use federal)	❌ (use federal)	❌ (use federal)
DACA/TPS	❌ (age not covered)	✅	✅ (no freeze)
UNDOCUMENTED	❌ (age not covered)	✅	⚠️ (freeze - existing only)

Solution

1. New parameter: ca_state_funded_immigration_statuses

values:
  2016-01-01:
    - UNDOCUMENTED
    - DACA
    - TPS
    - DACA_TPS

2. New parameter: medi_cal_enrollment_freeze/affected_statuses

values:
  2026-01-01:
    - UNDOCUMENTED

3. Updated formula logic

• Check if person's status is in CA state-funded list
• For 2026+: distinguish freeze-affected (UNDOCUMENTED) vs exempt (DACA/TPS)
• Freeze-affected: need continuous coverage or age exemption
• Freeze-exempt: always eligible (Health4All covered all ages by 2024)

Note on Oct 2026 (OBBBA)

After October 2026, federal OBBBA removes refugees, asylees, parolees, PRUCOL, and others from federal Medicaid funding. Whether CA will cover these groups with state funds is uncertain as of January 2026:

• Current state law: keep full-scope Medi-Cal with dental
• DHCS interpretation: move to Medi-Cal with no dental + premiums
• Governor's proposed budget (Jan 9, 2026): restricted-scope only

This will be addressed in a future update when legislation clarifies.

References

• California Welfare and Institutions Code Section 14007.8
• WCLP - Medi-Cal Immigration Changes Practice Tip (Jan 2026)
• 8 USC § 1641 - Definition of qualified alien