Hard for us to say.
"Coverage is considered unaffordable if the individual’s required contribution is more than 8.24% of applicable household income.
Use the Affordability Worksheet on page 10 to determine whether this coverage exemption applies to you or another member of your applicable household for one or more months of the year. "
You will need to get a copy of the Instructions for form 3853 and fill out that worksheet. Off the top of my head, I would guess that since she has access to your HDHP policy, that she would not qualify; however, I don't know how California calculates her "required contribution".
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