[MaxGhenis]

The Maryland Public Assistance to Adults (PAA) and California State Supplementary Payment (SSP) formulas now count each month's SSI in-kind support and maintenance (ISM) in that month. The California change applies to a couple in which one spouse receives SSI and the other qualifies for the Cash Assistance Program for Immigrants (CAPI). Both formulas previously spread the year's ISM across twelve equal months. The Maryland formula also reads each month's SSI couple status, as _ssi_couple_income has since #10820, and each month's income deemed from an ineligible spouse, as SSI's monthly formulas have since #10837.

Changes

• md_paa_countable_income becomes a monthly variable. It applies SSI's $20, $65 and one-half exclusions to each month's income and reads that month's ISM. md_paa and md_paa_imputed_federal_ssi already read it by month.
• md_paa_countable_income reads ssi_couple_computation_applies for the month, the same month _ssi_couple_income reads when it combines a couple's income. A spouse's part-year facility stay now separates the couple's income only in the months it covers.
• md_paa_countable_income adds the month's ssi_income_deemed_from_ineligible_spouse_monthly for citizens and qualified noncitizens. md_paa_imputed_federal_ssi reads the same variable.
• ca_state_supplement_person passes the month's income, with the month's ISM, to _apply_ssi_exclusions_monthly when it computes the SSI spouse's own countable income in such a couple. Its other paths already use monthly ssi_countable_income.

Sources

• Maryland pays "the amount by which the allowable needs exceed the net countable income in that month" (COMAR 07.03.07.09(A)), and applies its disregards to earned income "in any month" (COMAR 07.03.07.08(A)). Under the PAA Manual, section 900, caseworkers apply to earnings the part of the $20 disregard that unearned income under $20 leaves unused.
• SSA administers California's supplement and determines eligibility "using federal criteria" (CDSS). It determines a supplement's countable income "in the same manner" as SSI income (20 CFR 416.2025(b)).
• SSA uses "the in-kind support and maintenance you receive in the month" (20 CFR 416.1130(a)). It determines benefits "for each month", generally from income in the second prior month (20 CFR 416.420, POMS SI 02005.001).
• SSA counts an eligible couple's "combined income" (20 CFR 416.1802(b)(1)). In a month one spouse spends throughout in a medical treatment facility where Medicaid pays more than half the cost, it counts "each individual's own countable income" (20 CFR 416.414(a) and (b)(3)).
• When an ineligible spouse's remaining income exceeds the difference between the couple and individual rates, SSA treats the claimant and the spouse "as an eligible couple" (20 CFR 416.1163(d)(2)). It then values the claimant's ISM at no more than "one-sixth the couple Federal Benefit Rate (FBR) plus $10" (POMS SI 01320.150 B.1.a).
• SSA stopped counting food as ISM on September 30, 2024 (89 FR 21199), so it counts no food ISM in December 2024 payments, which use October income.
• The California cases use SSA's January 2024 payment levels (POMS SI 01415.056).

Methodology choices

• The Maryland formula counts SSI's ISM, with SSI's payment-month dating, for every PAA recipient. Neither COMAR 07.03.07.07 to .09 nor the PAA Manual has an in-kind support rule, and the formula counted SSI's ISM before this change. For an SSI recipient, imputed federal SSI moves by the opposite amount and PAA stays the same, while countable income stays under the federal benefit rate. For a PAA recipient with no SSI, the payment falls by each dollar of ISM above any part of the $20 exclusion that other unearned income leaves unused. Below that, each dollar of ISM moves a dollar of the exclusion off earnings, so a recipient with more than $85 of monthly earnings loses 50 cents per dollar. #10923 tracks whether Maryland counts ISM at all.
• The Maryland formula takes the $20 from unearned income first and moves any unused part to earnings, as PAA Manual 900 directs. Read literally, COMAR 07.03.07.08(A)(3) has DHS deduct all three disregards "from the total earned income", which counts $10 more for a person with at least $20 of unearned income and $85 of earnings.
• The Maryland formula still halves an SSI couple's combined income for each spouse, and now dates the couple status by month.
• The Maryland formula still adds the income SSI deems from an ineligible spouse for citizens and qualified noncitizens, and now dates it by month. COMAR 07.03.07.07 names no spouse income, and a comment in the formula marks the deemed amount as a known limitation.
• The California formula keeps the couple's presumed maximum value for the SSI spouse in a split couple, because PolicyEngine's SSI still computes the pair as a couple (#10481). SSA treats a spouse who fails its citizen or qualified-noncitizen test as an ineligible spouse (20 CFR 416.1160(d)). When it deems no income from that spouse, it values the claimant's ISM at no more than one-third of the individual rate plus $20 (POMS SI 01320.150 B.1.b). In 2024 that value comes to $334.33. The model's couple value comes to $491.67, where SSA's tables list $491.66.

Examples

A 70-year-old in a Maryland Level C care home receives food from others all through 2024. ISM equals $334.33 (one-third of the $943 federal rate plus $20) from January to November and $0 in December.

2024	Countable income before	Countable income now
January	$286.47	$314.33
November	$286.47	$314.33
December	$286.47	$0.00
Year	$3,437.67	$3,457.67

Before, the formula took $3,677.67 of annual ISM, divided it by 12 and subtracted $20 each month. December's unused $20 exclusion no longer offsets income in other months, so annual countable income rises by $20. An SSI recipient's PAA payment stays at $328 in January and $332 in November and December, because imputed federal SSI moves by the opposite amount. A PAA recipient with no SSI gets $956.67 in January (before, $984.53) and $1,275.00 in December (before, $988.53).

A 72-year-old citizen in California receives food from others all through 2024, and their 68-year-old spouse qualifies for CAPI.

2024	SSP before	SSP now
January	$280.58	$239.61
November	$280.58	$239.61
December	$44.75	$475.44
Year	$3,131.13	$3,111.15

Through November the citizen's SSI of $471.67 and SSP of $239.61 sum to $711.28: the $1,182.94 individual standard less $471.67 of own countable income, with the supplement rounded up to the cent. In December SSI of $707.50 and SSP of $475.44 sum to $1,182.94.

A 2025 Maryland couple aged 72 and 70 has $1,000 a month of wages and $1,000 of unearned income for the first spouse and $500 of unearned income for the second. The second spouse spends July to December in a Medicaid-funded facility.

2025	First spouse before	Second spouse before	First spouse now	Second spouse now
June	$1,447.50	$480.00	$973.75	$973.75
July	$1,447.50	$480.00	$1,447.50	$480.00
Year	$17,370.00	$5,760.00	$14,527.50	$8,722.50

Before, the annual formula applied December's status, separate, to the whole year. Now each spouse counts half of the couple's $1,947.50 from January to June and their own income from July. The spouses' annual values now sum to $23,250, the couple's income net of exclusions.

Invariants and tests

• A change to December's ISM moves December alone in Maryland's countable income, imputed SSI and PAA and in California's supplement, and each annual value equals the sum of its months (test_state_readers_keep_a_december_ism_change_in_december).
• Constant ISM returns the earlier annual result (test_constant_ism_keeps_the_annual_exclusion_result).
• With ISM under $20, Maryland's countable income follows PAA Manual 900, under which DHS applies the unused part of the $20 disregard to that month's earnings. Each month keeps its own disregards, since DHS takes them "in any month" under COMAR 07.03.07.08(A). California's supplement equals the $1,182.94 aged standard less $600 of SSI and that month's countable income in every month, December included (test_state_readers_keep_a_small_ism_exclusion_in_its_month).
• md_paa_countable_income.yaml adds January, November, December and full-year 2024 cases, and its part-year facility case checks June, July and the year. The spouses' annual values sum to the couple's income net of exclusions.
• For a citizen or qualified noncitizen with an ineligible spouse, Maryland's countable income for a month equals the claimant's own countable income plus that month's deemed income. A 2026 case with $2,000 a month of spouse wages and shelter support in July alone checks $957.50 in January and $238.50 + $967.50 = $1,206 in July.
• ca_state_supplement.yaml adds the SSI and CAPI couple in the same three months.

Pull request run 43676202506 at cecda1e28c passed all 37 jobs on GitHub's merge with main a29c73d587.

Microsimulation impact

We estimate no change in payments in 2026 on the default dataset. Maryland's Public Assistance to Adults totals $0 on main and on this branch, and neither California's state supplement nor SSI moves. Maryland's countable income for the program rises by $2,130, for 617 sampled people (952,049 weighted). We compared main at 70b8ccc15a with this branch at cecda1e28c.

Output	Main total	Change	Records changed (weighted)
md_paa	$0	$0	0 (0)
md_paa_countable_income	$249.3bn	+$2,130	617 (952,049)
ca_state_supplement	$2.52bn	$0	0 (0)
ca_state_supplement_person	$2.52bn	$0	0 (0)
ssi	$56.68bn	$0	0 (0)
state_income_tax	$576.5bn	$0	0 (0)
income_tax	$2,594.9bn	$0	0 (0)
household_benefits	$2,060.2bn	$0	0 (0)
household_net_income	$17,246.6bn	$0	0 (0)

Related work

• #10820 combined an SSI couple's income by each month's couple status through _ssi_couple_income, and #10856 added earnings to the Maryland part-year case.
• #10837 computes income deemed from an ineligible spouse for each month, with the claimant's ISM in both budgets.
• #10532 also changes the Maryland income reader and both amended YAML files.
• #10146 changes adjacent SSI deeming and rewrites the same own-income lines of ca_state_supplement_person, so whichever lands second resolves them. #10639 changes adjacent resource tests.
• #10923 asks whether DHS counts SSI's in-kind support as PAA income at all. If it does not, its fix removes the ISM term this change dates by month, and the Maryland ISM examples above change with it.
• medicaid_optional_senior_or_disabled_countable_income stays annual and still sums the year's ISM.

Axiom parity

axiom: TheAxiomFoundation/rulespec-us#1940 queued (Maryland PAA countable income under COMAR 07.03.07.08 and .09 and PAA Manual 900, and California's own-income path for the SSI spouse of a CAPI-eligible spouse, both by month; the corpus lacks the PAA Manual, and the pinned release lacks COMAR 07.03.07 and 20 CFR part 416, so the signed encoder can't run yet)

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[MaxGhenis]

US + core hub merge audit, us#10809 at cecda1e28c7ef2612ebe58deff57febcae966188 (squash): Read monthly SSI support in Maryland and California benefits.

• Reviews:
  • The PR has no GitHub reviews. Three independent review rounds ran outside GitHub, with a fix round after each of the first two.
  • The first round, at 2c307bb153, read 20 CFR 416.420, 416.1123, 416.1130 and 416.2025 and 89 FR 21199 on govinfo, POMS on secure.ssa.gov, COMAR 07.03.07.08 and .09 and PAA Manual 500 and 900. It computed the 2024 Maryland and California figures by hand and ran them on the head and on the merge base, and every value agreed.
  • It found that Combine an SSI couple's income by each month's facility status #10820, merged after the PR's base, made a clean textual merge with main wrong. The merged formula combined a couple's income by each month's status and halved it by December's. A couple with a facility stay from July then counted the combined income, unhalved, for each spouse from January to June. It also found a stale description, no population estimate and no Maryland rule for counting SSI's in-kind support (ISM), and it suggested an example with ISM under $20.
  • The first fix round, ending at f53c22729a, merged main and read the couple status for the month. It re-derived the part-year case for June, July and the year, moved California's own-income path to the monthly exclusions and added a property test for ISM under $20.
  • The second round, at f53c22729a, found no defect in the code or tests. One script reproduced the double count on the merged tree before the fix, [20,370, 14,565] for the year, and returned the hand values at the head, [14,527.50, 8,722.50]. It searched all 11 sections of the PAA Manual for an in-kind support rule and found none.
  • It listed four minor findings. A test comment credited COMAR with taking the $20 from unearned income first, and the new test never checked California's December payment. Three description sentences needed edits, and the axiom: line named issues that don't cover the change. It left seven test runs and four mutants owed, and a later pass asked the description to link The model counts SSI's presumed value of in-kind support as Maryland PAA income #10923.
  • The second fix round ran from f03789a370 to cecda1e28c. It credited PAA Manual 900 in the test comment, asserted California's payment in every month and merged main twice. The second merge brought Apply SSI's general exclusion once under spousal deeming #10837, which computes spouse-deemed income by month. cecda1e28c then moved md_paa_countable_income to that month's amount and added a case with shelter support in July alone.
  • That round ran the owed files, and each of four mutants failed at least one case: the annual couple status, annual ISM in each formula, and a $20 exclusion with no carry to earnings. A fifth, the annual deemed amount, gave $958.33 in January, where the new case expects $957.50, and the third round confirmed that figure by hand.
  • The third round reviewed the four new commits at cecda1e28c and found the code, the tests and both merges correct. It recomputed the new case by hand, matched the pre-merge runs and four mutants to their logs and read run 43644937990, which passed all 38 jobs at the head merged into main at 94054aa57e. The run covered 9 cases in the Maryland file, 22 in California's, the three property tests and the Household API Partners job.
  • It requested changes for one gap: the axiom: line named three rulespec-us issues that don't cover this change, where Encode income counting under SSI methodology, with spouse deeming, for aged, blind and disabled people who fail SSI's noncitizen test (42 CFR 435.601(b); 20 CFR 416.1163) (PE-US PR 10240) TheAxiomFoundation/rulespec-us#1940 does. It also listed four description edits. Before merge I made those edits, commented on Encode income counting under SSI methodology, with spouse deeming, for aged, blind and disabled people who fail SSI's noncitizen test (42 CFR 435.601(b); 20 CFR 416.1163) (PE-US PR 10240) TheAxiomFoundation/rulespec-us#1940 and MS Dependents exemption #2191 and pointed the line at Add CA itemized deduction logic #1940.
  • I also corrected four more description sentences before merge. They now state where SSI stops offsetting Maryland's ISM, who computes California's split couple as a couple, which months the 2025 spouse spends in a facility, and whose income the deemed-income check covers. I added the order of Maryland's $20 disregard to the description's methodology choices, and SSA's listed couple value of $491.66 beside the model's $491.67.
• Methodology choices for maintainers:
  • The Maryland formula counts SSI's presumed value of ISM for every PAA recipient, and this PR dates it by SSI's payment month. Neither COMAR 07.03.07.07 to .09 nor the PAA Manual has an in-kind support rule, and The model counts SSI's presumed value of in-kind support as Maryland PAA income #10923 asks whether DHS counts it at all. A maintainer who reads Maryland as counting none would expect $0 where the January and November 2024 cases expect $314.33.
  • The Maryland formula takes the $20 from unearned income first and moves any unused part to earnings, as PAA Manual 900 directs and as SSA does for SSI. Read literally, COMAR 07.03.07.08A(3) has DHS deduct all three disregards "from the total earned income", which counts $10 more for a person with at least $20 of unearned income and $85 of earnings. The order predates this PR, the new property test pins it, and the source-conflict register has no entry for it.
  • The Maryland formula adds the income SSI deems from an ineligible spouse for citizens and qualified noncitizens, now by month. COMAR 07.03.07.07 names no spouse income, and a comment in the formula marks the term as a known limitation. In the 2026 case the claimant has no income in January and counts $957.50.
  • The California formula values the SSI spouse's ISM at the couple's presumed maximum in a split SSI and CAPI couple, because PolicyEngine's SSI computes the pair as a couple (Treat an aged, blind or disabled spouse who fails SSI's noncitizen test as an ineligible spouse, and base CAPI's mixed couple on actual SSI/SSP receipt #10481). SSA treats that spouse as ineligible. When it deems no income, it values ISM at no more than one-third of the individual rate plus $20 under POMS SI 01320.150 B.1.b. In the January 2024 case the model counts $471.67 of own income, where that reading counts $314.33.
  • Both formulas read other income as one-twelfth of the year's. They date food ISM by SSI's payment month, which counts food from the second prior month under 20 CFR 416.420(a). Under COMAR 07.03.07.09A, DHS compares needs with income "in that month", and the regulation names no budget month.
  • medicaid_optional_senior_or_disabled_countable_income stays annual and still sums the year's ISM.
• Gates checked live at merge:
  • gh pr checks exits 0;
  • the latest Pull request run at the head, 43676202506, passed and tested this head merged into main at a29c73d587;
  • MERGEABLE;
  • not a draft;
  • no reviewer's latest review requests changes;
  • the semantic-overlap guard: since a29c73d587, main has changed no area this PR touches. Between the PR's merge base 70b8ccc15a and main at a29c73d587, main changed 281 files and none of the six this PR touches. There Finish South Carolina TANF boundary and source follow-ups #10829 changed South Carolina TANF, Count gambling winnings in federal gross income and fix the wagering losses deduction #10070 changed gambling winnings and the wagering loss deductions, Add New York CCAP differentials and enhanced payment rates #10821 changed New York child care payment rates, and nine PRs added LIHEAP cooling assistance in nine states. Main changed no file under gov/ssa or Maryland DHS. In California, Count gambling winnings in federal gross income and fix the wagering losses deduction #10070 changed four itemized-deduction files and none under CDSS, and neither SSI income source list names gambling winnings. The branch merges into main at a29c73d587 without conflict;
  • the merge pins the head.
• Impact: we estimate no change in payments in 2026 on the default dataset, where Maryland's Public Assistance to Adults totals $0 on both sides and neither California's state supplement nor SSI moves. Maryland's countable income for the program rises by $2,130 (617 people, 952,049 weighted). Main 70b8ccc15a against cecda1e28c.
• Next:
  • The model counts SSI's presumed value of in-kind support as Maryland PAA income #10923 asks whether Maryland counts ISM at all. A fix that drops the term must build on this change. In md_paa_countable_income.yaml it must update the January, November and annual 2024 cases and the 2026 case's July and annual values. It must also update the Maryland assertions of all three property tests: the December, constant-ISM and small-ISM tests.
  • Limit SSI ineligible-child allocations to co-resident children and compute SSI and Medicaid deeming by month #10146 rewrites the same own-income lines of ca_state_supplement_person, lines 83 to 98 at this head. Whichever of the two lands second must resolve them and keep the month's ISM and the monthly exclusions.
  • Include farm and partnership earnings in SSI and correct loss netting #10532 edits md_paa_countable_income.py and appends cases to both YAML files. Its branch reads the couple status for the year, so its merge of main must keep the month's status at line 49 and both sides' cases.
  • File an issue to date ISM by month in medicaid_optional_senior_or_disabled_countable_income, which still sums the year's ISM and applies one annual exclusion.
  • File an issue on whether Maryland PAA counts income SSI deems from an ineligible spouse. COMAR 07.03.07.07 names none.
  • Record the order of Maryland's $20 disregard as a source-conflict candidate, PAA Manual 900 against COMAR 07.03.07.08A(3).
  • Treat an aged, blind or disabled spouse who fails SSI's noncitizen test as an ineligible spouse, and base CAPI's mixed couple on actual SSI/SSP receipt #10481 covers the couple status behind California's presumed value. Its fix should also value the SSI spouse's ISM under POMS SI 01320.150 B.1.b.
  • For a citizen under spouse deeming, md_paa_imputed_federal_ssi subtracts own and deemed income from the couple rate, with no cap at the individual computation of 20 CFR 416.1163(e)(2). That predates this PR and needs an issue.
• Axiom: Encode income counting under SSI methodology, with spouse deeming, for aged, blind and disabled people who fail SSI's noncitizen test (42 CFR 435.601(b); 20 CFR 416.1163) (PE-US PR 10240) TheAxiomFoundation/rulespec-us#1940 queued. A comment there records that this head moves md_paa_countable_income and California's own-income path to the month, and gives the law, the leaf inputs and ten companion rows. A comment on MS Dependents exemption #2191 replaces its annual Maryland part-year figures. The signed encoder can't run yet: the corpus holds no copy of the PAA Manual, and the release rulespec-us pins lacks COMAR 07.03.07 and 20 CFR part 416.

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