Model California county and litigation-reinstated statewide SNAP ABAWD waivers

[daphnehanse11]

Fixes #8868

Important

Stacked on #8860 — review only the commits after that branch point; merge #8860 first. This branch builds on snap-abawd-ak-borough-waivers and extends its waived-area mechanism.

Summary

Extends the SNAP ABAWD waived-area mechanism from #8860 with two additions:

1. California county waivers (7 U.S.C. 2015(o)(4)(A)(i), 7 CFR 273.24(f)): adds seven CA counties to gov.usda.snap.work_requirements.abawd.waived_county_fips effective 2025-11-01 through 2026-10-31 — Colusa (06011), Imperial (06025), Tulare (06107), Alpine (06003), Merced (06047), Monterey (06053), and Plumas (06063). The 2025-11-01 dated entry retains all 29 Alaska boroughs/census areas (the AK good-faith exemption runs through 2026-10-31), and the combined list ends 2026-11-01.
2. Litigation-reinstated statewide waivers: new dated list parameter gov.usda.snap.work_requirements.abawd.waived_states covering the statewide waivers USDA terminated in November 2025 and — after Rhode Island State Council of Churches v. Rollins (D.R.I. No. 1:25-cv-00569, TRO 2025-10-31) — kept in effect through their original expiration dates per USDA's February 26, 2026 guidance. is_in_snap_abawd_waived_area now returns true when the household's state is in this list, in addition to the county FIPS check. Because the waiver sits in base_conditions of meets_snap_abawd_work_requirements, it applies under both the pre-HR1 and post-HR1 branches (tested in both).

Source provenance (per parameter value)

waived_county_fips — CA counties, 2025-11-01 → 2026-10-31 (primary sources, verified)

Counties	Source	Basis
Colusa, Imperial, Tulare	CDSS ACL 25-79 (Nov 7, 2025) with attached FNS approval (Oct 23, 2025)	12-month average unemployment >10% (13.0% / 18.7% / 10.4%, Jul 2024–Jun 2025 BLS data)
Alpine, Merced, Monterey, Plumas	CDSS ACL 26-15 (Feb 26, 2026) with attached FNS modification approval (Feb 10, 2026)	3-month average unemployment >10%; retroactively effective Nov 1, 2025

Both FNS enclosures state implementation 2025-11-01 and expiration 2026-10-31. I read both ACL PDFs directly, including the FNS waiver-response enclosures.

waived_states — statewide waivers (primary sources for scope and windows; guidance table for reinstated expirations)

Verified STATEWIDE from FNS FY2025 waiver response letters (fns-prod.azureedge.us):

State	Verified window	Sources
CA	statewide 2024-11-01 → 2025-10-31, replaced by statewide waiver effective 2025-02-01 (response a, response b)	reinstated expiration 2026-01-31 per USDA guidance table
IL	statewide 2024-11-01 → 2025-10-31, replaced by statewide waiver 2025-02-01 → 2026-01-31 (a, b)	FNS partially approved 12 of 24 requested months
NV	statewide since 2024-07-01; replacement statewide waiver 2025-02-01 → 2026-01-31 (response)	modeled from 2024-11-01 (parameter's modeling start)
DC	districtwide 2024-12-01 → 2025-11-30, replaced by districtwide waiver effective 2025-01-01 (a, b)	reinstated expiration 2025-12-31 per USDA guidance table

Resulting dated values: [CA, IL, NV] from 2024-11-01 → [CA, DC, IL, NV] from 2024-12-01 → [CA, IL, NV] from 2026-01-01 (DC expired) → [] from 2026-02-01.

What I could NOT verify from primary sources, and how it is handled:

• The USDA Feb 26, 2026 guidance expiration table itself. USDA has not published it on a stable public page; the expiration cohorts (CT, KY → 2025-11-30; DC, NM, OR → 2025-12-31; CA, IL, NV, NJ, WA → 2026-01-31; MI, NY, RI → 2026-02-28; MN, MT, ND → 2026-06-30) come from Ballotpedia's OBBBA implementation tracker report of the guidance (its table renders as an image; the accompanying text confirms the guidance reinstated the 18 terminated waivers through original expirations). Labeled as such in the parameter references.
• 12 of the 16 reinstated waivers were PARTIAL-state, not statewide, per the FNS FY2025 response letters I read: CT (68 towns), KY (117 counties), MI (80 counties + 3 cities + 10 reservations), MN (17 counties + 9 reservations), MT (6 reservation areas), NJ (20 counties), NM (29 counties + 18 reservations), NY (61 of 62 counties), OR (30 counties + 7 reservation areas), RI (9 towns), WA (38 counties + 1 reservation area), plus ND (partial per the FY25 Q2 waiver status report; its response letter was not retrievable). These are not modeled — sub-state coverage would need county FIPS (or sub-county, for towns/reservations) encoding. Documented in the parameter header, and pinned by a test (NY resident in 2026-02 is not exempt).
• CA/DC approval-letter vs guidance-table end dates. The CA replacement approval letter runs through 2027-01-31 and the DC letter through 2026-12-31, but the USDA guidance table lists 2026-01-31 and 2025-12-31 respectively. The parameter follows the guidance table (which governs post-litigation administration; CDSS implemented the time limit statewide 2026-06-01 per ACL 25-93). The discrepancy is documented in the parameter header.
• Waivers before 2024-11-01 (e.g., NV's statewide waiver from 2024-07-01) are outside this parameter's modeling window, consistent with Model Alaska borough-level SNAP ABAWD waivers #8860.

Interaction with HR1 (pre/post composition)

is_snap_abawd_hr1_in_effect for CA is false until 2026-06-01 (ACL 25-93). The waiver is part of base_conditions, so it exempts in both branches:

• pre-HR1 branch: IL 2025-06 (Case 15), CA 2025-12 (Case 10), Tulare County 2026-03 (Case 7)
• post-HR1 branch: NV 2026-01 (Case 11), DC 2025-12 (Case 13), Tulare County 2026-07 after CA adopts HR1 (Case 9)

Because state_code defaults to CA, three pre-existing tests in meets_snap_abawd_work_requirements.yaml began picking up the CA statewide waiver; they were adjusted minimally while preserving intent (Cases 4 and 25 now pin state_code: TX; Case 32 moved from 2026-01 to 2026-03, after the CA statewide waiver expires but still pre-HR1 for CA).

Tests

uv run policyengine-core test policyengine_us/tests/policy/baseline/gov/usda/snap/eligibility/work_requirements -c policyengine_us
======================== 77 passed, 1 warning in 7.82s =========================

Broader regression runs (both clean):

uv run policyengine-core test policyengine_us/tests/policy/baseline/gov/usda -c policyengine_us
================== 481 passed, 1 warning in 152.41s (0:02:32) ==================

uv run policyengine-core test policyengine_us/tests/policy/baseline/gov/hhs/medicaid/eligibility -c policyengine_us  # consumes meets_snap_abawd_work_requirements
uv run policyengine-core test policyengine_us/tests/policy/baseline/partners -c policyengine_us
================== 191 passed, 1 warning in 128.33s (0:02:08) ==================

Note on test conventions: year-defined inputs (state_code, age, etc.) are keyed by year (e.g. state_code: {2026: NV}) in the new cases because their test periods are non-January months; unkeyed year inputs at such periods fail to build in the YAML test runner.

🤖 Generated with Claude Code

[codecov]

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 100.00%. Comparing base (fa285ae) to head (65b9af3).
⚠️ Report is 640 commits behind head on main.

Additional details and impacted files

@@            Coverage Diff            @@
##              main     #8872   +/-   ##
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  Coverage   100.00%   100.00%           
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  Files            5         2    -3     
  Lines           62        47   -15     
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- Hits            62        47   -15     

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[MaxGhenis]

Held as draft pending a source decision (not a code problem)

Assessed and rebased-tested this branch on current main; the code and the county-level data are sound. Keeping it draft for one reason: the litigation-reinstated statewide-waiver expiration table in waived_states.yaml is sourced from Ballotpedia (as the header notes, "USDA has not published the table on a stable public page"). Encoding specific per-state expiration dates in the model from a secondary source is the one spot in this series that needs firming up. Two acceptable paths:

1. Primary cite — locate the USDA February 26, 2026 post-Rhode Island State Council of Churches v. Rollins guidance (or the state-agency implementation notices that restate it) and cite that directly for each state/date; or
2. Documented approximation — reframe the waived_states values explicitly as an approximation of that guidance, with the Ballotpedia table cited as the interim basis and a clear "verify against primary source" note, consistent with how other unverifiable-at-source values are handled.

Separately, the fully-verified portions could ship sooner if wanted: the seven CA county waivers (ACL 25-79 + ACL 26-15, all FIPS confirmed) and the AK borough list (already in #8860) are primary-source-clean. If it's useful, the CA county additions can be split into their own PR on top of #8860 and merged independently of the statewide-waiver question.

What's verified on this branch as-is:

• CA county FIPS (Alpine 06003, Colusa 06011, Imperial 06025, Merced 06047, Monterey 06053, Plumas 06063, Tulare 06107) — all correct; waiver window 2025-11-01 through 2026-10-31 confirmed via CDSS ACL 25-79 and ACL 26-15.
• Tests pass on the rebased branch.

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Note on the base: #8860 (the branch this is stacked on) was just rebased onto current main and force-pushed (its shared-formula edit was union-merged with the discretionary-exemption and foster-youth changes that landed from #8870/#8871). When you pick this back up, rebase this branch onto the updated snap-abawd-ak-borough-waivers (or directly onto main) so it no longer carries #8860's old commits. Leaving it as draft until then.