I think changing the base pay at a 1:1 rate with tips is prohibited and is just using shell game accounting that a court can easily pierce.

The issue is that the statue explicitly calls out tips, not base salary. I'm not a lawyer nor has this been brought to court so it's speculation on everyone's part. Shell games are not inherently illegal and depending on the judge they will declare that the legislation should have been more clear or that the shell game doesn't live into the 'spirit of the law'.

''Service employee'', a person who works in an occupation in which employees customarily receive tips or gratuities, and who provides service directly to customers or consumers, but who works in an occupation other than in food or beverage service, and who has no managerial responsibility.

The definition of service employee is contingent on them first being an "employee", which is a separate designation from an independent contractor. Even if their responsibilities are similar.

Here's a lawsuit that's about Uber and their drivers who are considered independent contractors in CA & MA. Long story short they are still independent contractors of Uber not employees. I'd wager Doordash drivers are in a similar situation.