New York CCAP: stop an enhanced-rate legally exempt group payment at the actual cost of care #10964

What the regulation requires

18 NYCRR 415.9(g)(7) lets a legally exempt group child care program receive an enhanced market rate and differentials together. Under that paragraph, a district's total payment to such a program can't exceed the lesser of two amounts: 100% of the day care center market rate, and the actual cost of care. The paragraph reads this way in OCFS's Part 415 compilation current as of February 13, 2024 (PDF page 47).

On page 9 of 24-OCFS-LCM-22, OCFS limits a group program's payment before differentials to the lesser of its cost and its market rate. It limits the payment with differentials only to the day care center rate.

What the model does

After #10821, ny_ccap_payment_rate applies the combined differential to the lesser of the child's expenses and market rate. For a legally exempt group program (LE_GC), it then stops the payment at ny_ccap_day_care_center_rate. It applies no cost limit to the total, so a differential can lift an enhanced-rate group program's payment above its cost. Only New York City's group programs get an enhanced rate in the model, when they meet the health or the training requirement.

No test checks a group payment against the program's cost. Both LE_GC payment cases in ny_ccap_payment_rate.yaml set expenses of $3,000, above the center rate, and test_ny_ccap_rates_invariants.py checks the center-rate limit alone.

Proposed change

• Confirm paragraph (7) in the current Part 415. OCFS amended Part 415 on December 24, 2025 (I.D. No. CFS-10-25-00002-A), and the State Register notice doesn't print the amended text.
• If the cost limit stands, stop the payment to an LE_GC program with an enhanced rate at the lesser of the child's expenses and ny_ccap_day_care_center_rate.
• Record the difference between paragraph (7) and LCM-22 in source_conflicts/candidates.yaml.

Tests

• A New York City group program with an enhanced rate that charges less than that rate, with a differential: the payment equals the charge.
• The same program when it charges more than its enhanced rate and less than the center rate, with a differential that lifts the payment above the charge: the payment stops at the charge.
• A group program with the standard rate and a differential keeps the payment it gets now.
• The two existing cases with $3,000 of expenses keep their center-rate results.
• A property in test_ny_ccap_rates_invariants.py: no payment to an enhanced-rate LE_GC program exceeds the child's expenses.