[MaxGhenis]

Apply New York CCAP's payment differentials and special-needs market rate, and New York City's enhanced informal and legally exempt group rates. OCFS sets these rules in 24-OCFS-LCM-22, and districts apply them under 18 NYCRR 415.9. The Legislature raised the mandatory minimum from April 1, 2025, in Social Services Law 410-x(10).

Districts apply each differential to the lesser of the child's allocated expenses and the applicable market rate, and subtract the family share once from total payments. A district can then pay a licensed, registered or informal provider more than it charges. The model stops a legally exempt group payment at the day care center rate that applies to the child.

Closes #10706
Closes #10707

Differential rates

Differential	Providers	From October 1, 2024	From April 1, 2025
Nontraditional hours	all eligible providers	5% to 15%	10% to 15%
Homelessness	licensed or registered	5% to 15%	10% to 15%
Homelessness	legally exempt	optional, up to 15%	optional, up to 15%
Accreditation	licensed or registered	optional, 5% to 15%	optional, 5% to 15%

OCFS states the October 2024 ranges in LCM-22 (pages 9-10), which repeat 415.9(f). The Legislature set the April 2025 floors in subdivision 10 of 410-x. Districts must set a differential for homelessness care by licensed or registered providers (paragraph a) and for nontraditional hours with licensed, registered or enrolled providers (paragraph b). Each must be "no less than ten percent higher but no greater than fifteen percent higher". The nysenate.gov copy of the section from December 2024 marks subdivision 10 "Effective April 1, 2025".

OCFS limits combined differentials to 25% of the lesser of cost and market rate, unless it grants a district a waiver. It raised that limit to 35% in a rule (proposed March 12, 2025) that it adopted without change, effective December 24, 2025 (notice of adoption).

New York City pays 15% for nontraditional hours. Monroe County pays 10% for accreditation and 5% for legally exempt homelessness care. Elsewhere, the model pays the minimum for mandatory differentials and nothing for optional ones.

Special-needs rate

A child with a disability qualifies for the special-needs rate when the parent shows a need for extra care and the child's cost exceeds the regular rate. OCFS sets that rate at 115% of the regular rate, and districts apply differentials to it (LCM-22, page 7). The model raises the day care center rate that caps a legally exempt group payment for that child by the same 115%.

New York City enhanced rates

ACS pays enhanced informal rates at 75% of family day care rates under FS-023. Group 4 contains only New York City's five counties, so its weekly, daily and part-day cells use those published amounts.

For legally exempt group programs, ACS lists rates that equal 81% of center rates when the program meets either the health or the training requirement, and 87% when it meets both. Under 415.9(g), a district can pay no more. ACS lists each rate in whole dollars, and the model prices scheduled and excess periods from those cells. Rates below age three stay zero.

Validation

Pull request run 43654879593 at d7c1548c2e passed all 37 jobs on GitHub's merge with main 7c516c74bb.

On this head, which merges main at 3ab9b19:

• rates/ny_ccap_payment_rate.yaml: 31 of 31 cases pass. They cover each differential, provider scope, the 5% and 10% minimums, individual bounds, the 25% and 35% limits, a waiver, costs, special needs, Monroe County from November 2024 to January 2026, expense allocation and family share.
• In a new April 2025 case, a district configures 0% for nontraditional hours and for licensed homelessness care and pays the 10% minimum: $1,000 × 1.10 = $1,100. Moving the April 1, 2025 date in minimum.yaml to May 1 fails that case alone, because the district then pays 5%.
• The payment file uses two parameter-override sets and peaks at 5.0 GB in policyengine-core test on macOS. The PR raises the New York test folder from four distinct override sets to six.
• rates/ny_ccap_market_rate.yaml: 60 of 60 pass. ny_ccap.yaml: 37 of 37. ny_ccap_activity_eligible.yaml: 9 of 9. integration.yaml: 6 of 6.
• test_ny_ccap_rates_invariants.py: 1 of 1 passes. It checks each generated child's special-needs condition and group cap, and reads the 115% multiplier from the parameters.
• test_ny_ccap_categorical_routes_invariants.py: 4 of 4 pass. test_programs_registry.py: 883 pass and 10 skip. test_reference_urls.py: 32 pass. test_source_conflicts.py: 103 pass.
• Ruff format, Ruff lint and git diff --check pass.

At 24ee73c, before the April 2025 district case and the merge with main, each of six mutants, one per changed rule, fails at least one case:

• dropping the April 2025 10% minimum fails 2 payment cases;
• flooring accreditation at the mandatory minimum fails 1;
• dropping the licensed homelessness floor fails 3;
• dropping the December 2025 35% limit fails 2;
• capping a special-needs child's group payment at the regular center rate fails 1;
• granting the special-needs rate when expenses equal the regular rate fails 1 market-rate case.

Invariants

test_ny_ccap_rates_invariants.py checks the first six properties in January 2025, and the YAML cases pin the dated minimums and limits.

• With all five new inputs false and homelessness false, market rates and benefits equal main's outside New York City's enhanced informal cells, which rise.
• Legally exempt group payments never exceed the day care center rate that applies to the child: the regular center rate, or 115% of it for a child who qualifies for the special-needs rate.
• Each differential weakly raises payment and never lowers the family benefit.
• Without an OCFS waiver, combined differentials never exceed 25% of the lesser of expenses and the applicable market rate (35% from December 24, 2025).
• The special-needs rate equals 115% of the regular rate only with disability, the parent's showing, and expenses above the regular rate.
• Family benefits stay nonnegative, and all five new inputs default to false.
• From April 1, 2025, the nontraditional-hours differential, for any provider, and the homelessness differential for licensed or registered providers pay at least 10%, and an elected accreditation differential pays at least 5%.

Microsimulation impact

We estimate no change in 2026 on the default dataset, where New York's child care subsidy totals $0 on main and on this branch. None of the seven measured outputs moves. We compared main at 3ab9b19a11 with this branch at d7c1548c2e.

Output	Main total	Change	Records changed (weighted)
ny_ccap	$0	$0	0 (0)
ny_child_care_subsidies	$0	$0	0 (0)
child_care_subsidies	$1.72bn	$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)

Methodology choices

1. Cap a legally exempt group payment for a child who qualifies for the special-needs rate at 115% of the center rate. In LCM-22, OCFS calls the special-needs rate "the market rate for that child" (page 7) and caps group payments at "100% of the applicable market rate for day care centers" (page 9). For a New York City preschooler in a group program with both enhancements, the special-needs rate and the 15% nontraditional rate, the cap rises from $1,902.33 to $2,187.68 a month. The model applies that center-rate limit alone. Under 415.9(g)(7), when a group program receives an enhanced rate and one or more differentials, a district's total payment also can't exceed the actual cost of care. The model applies no such limit.
2. Apply the 35% limit to every district from December 24, 2025, so monthly calculations first read it in January 2026. OCFS stated the 35% figure in its summary of the proposed rule and adopted the rule without changes. In the proposal's impact statement, OCFS says districts must amend their plans to reflect a change in the maximum combined percentage. Monroe County's approved plan states a 25% total and requests no waiver. The model assumes a district needs no plan amendment to pay up to 35%, so it pays Monroe's 30% in January 2026. The same rule adds optional differentials for QUALITYstarsNY and the auto-injector initiative, which this PR leaves out.
3. Use New York City's 15% nontraditional differential from the October 2024 schedule. City officials described that rate in September 2023 testimony; its exact start date remains unverified. ACS lists no differential rates in FS-023, so the model uses the state defaults for the city's homelessness and accreditation rates.
4. Use Monroe County's 10% accreditation and 5% legally exempt homelessness differentials from its approved plan. OCFS approved the plan effective November 18, 2024, so monthly calculations first read those rates in December. From April 2025, Monroe must pay at least 10% for nontraditional hours and licensed homelessness care under 410-x(10), so the model raises its 5% rates to 10%.
5. Elsewhere, pay the state defaults: the minimum for mandatory differentials and nothing for optional ones.
6. Keep standard legally exempt group rates outside New York City. Monroe County declined both group enhancements in its plan.
7. Keep main's 70% enhanced informal rates outside New York City. Monroe County chose 75% in its approved plan, which a follow-up can add as a county override.
8. Allocate family expenses equally among all children in paid care, including ineligible siblings, as main does. Use is_disabled as the special-needs proxy, require the parent's showing, and compare each child's allocated costs with their regular rate.
9. Represent an OCFS waiver through the combined-limit parameter, with no waiver by default. Annual inputs record qualifying care and provider status without inferring them from hours or provider type.
10. When a household reports nontraditional-hours care, apply that differential to the child's whole monthly payment. Districts pay it on care during those hours, and the model's inputs don't split care by hour.
11. Let a differential raise a payment above what the provider charges. Under 415.6(e)(1), the state reimburses a district only for payments that don't exceed the actual cost of care. In 410-x(10) and 415.9(f), the Legislature and OCFS set each differential above the lesser of cost and market rate, and the model follows those two provisions.

LCM-22 citations refer to the version OCFS issued on August 21, 2024. The 415.6 and 415.9 page anchors follow OCFS's Part 415 compilation current as of February 13, 2024, which we read from an Internet Archive copy of May 22, 2024. That compilation predates the 10% minimums and the 35% limit.

In programs.yaml, the New York entry describes the modeled differentials, the special-needs rate and New York City's enhanced rates, with state and local defaults. It keeps #10817's sentences on categorical routes, activity conditions and family share exceptions. New York remains partial.

axiom: TheAxiomFoundation/rulespec-us#2244 queued (Social Services Law 410-x(10), 18 NYCRR 415.9 and 24-OCFS-LCM-22; the corpus lacks section 410-x, OCFS Part 415 and LCM-22, so the signed encoder can't run yet)

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[MaxGhenis]

US + core hub merge audit, us#10821 at d7c1548c2ec8bfc2a712fbdb95fb883e12970bdd (squash): Add New York CCAP differentials and enhanced payment rates.

• Reviews:
  • The PR has no GitHub reviews. Three independent review rounds ran outside GitHub, with a fix round before the second and another before the third.
  • The first round, at 2d30c5dd26, read 24-OCFS-LCM-22 pages 7 to 10, ACS form FS-023, Monroe County's plan and Social Services Law 410-x(10). It computed 16 households by hand and ran them on the head, and all 16 matched. Three of them also ran on the merge base 935b24ff4f. It matched all 24 New York City enhanced cells to FS-023.
  • It found that the 5% minimums ran past April 1, 2025, when the Legislature raised them to 10% in 410-x(10). An Albany preschooler in center care during nontraditional hours got $1,547.00 a month in June 2025, where the law requires at least $1,620.67.
  • It also found that a legally exempt group payment stopped at the regular center rate for a child with the special-needs rate. The payment test file built six parameter-override sets and didn't finish under an 8 GB cap. No case covered the licensed homelessness minimum, a month after April 2025 or Monroe County before December 2024.
  • The fix round, in 24ee73c6d4, raised the two mandatory minimums to 10% from April 1, 2025 and gave an elected accreditation differential its own 5% minimum. It raised the combined limit to 35% from December 24, 2025 and multiplied the center limit by 115% for a child with the special-needs rate. It cut the payment file to two override sets and added the missing cases. Each of six mutants failed a case.
  • The second round, at 24ee73c6d4, read 410-x in an archived copy of the Senate's page, both State Register issues and Monroe County's plan. It ran 23 households through ny_ccap and recomputed all 30 payment expectations by hand, and every figure matched. The payment file passed all 30 cases with a 5.64 GB peak, and each of six rule mutants failed a case.
  • It found no defect in the new code and listed four minor points. No case pinned the April 2025 date of the minimum where the default district rates didn't mask it. The Monroe County case for January 2026 assumed a 35% limit without a plan amendment. Two reference titles left out a page, and the property test restated the payment formula with a literal 1.15.
  • The next fix round, in 5ca8629a3f, added an April 2025 case where a district sets 0%, and moving the minimum's date to May 1 fails that case alone. It added the pages to both titles, dropped the restated assertion and read the multiplier from the parameters.
  • d7c1548c2e merges main at 3ab9b19a11, since Fix New York child care categorical routes and family shares #10817 had changed the New York CCAP notes in programs.yaml. That line held the merge's one conflict, and the merged line keeps each side's additions and removals.
  • The third round, at d7c1548c2e, checked the merged notes sentence by sentence against both parents and recomputed the April case by hand. It read CI at the head: all 36 checks passed, with 31 payment cases, 60 market-rate cases, 6 integration cases and the property test. It found the code, the minor fixes and the merge correct.
  • It asked for two changes to the description, a queued axiom: line and a government source for 18 NYCRR 415.9, and I made both before merge. It also asked for a follow-up issue on Monroe County's 75% enhanced informal rate, listed under Next.
  • For the 415.9 link, I read OCFS's Part 415 compilation current as of February 13, 2024. Under its paragraph (g)(7), when a legally exempt group program receives an enhanced rate and one or more differentials, a district's payment can't exceed the actual cost of care or the center rate. No review round covered that paragraph. The description now states the difference, and Next lists the follow-up.
• Methodology choices for maintainers:
  • A legally exempt group payment for a child with the special-needs rate stops at 115% of the center rate. In LCM-22, OCFS calls the special-needs rate "the market rate for that child" on page 7 and limits group payments to the "applicable market rate for day care centers" on page 9. A maintainer who reads that limit as the regular center rate would expect $1,902.33 a month in the New York City case, where the model pays $2,187.68.
  • The model applies the center-rate limit alone to a legally exempt group payment, as OCFS states it in LCM-22. Under 415.9(g)(7), in the February 2024 compilation, the payment to a program that receives an enhanced rate and one or more differentials also can't exceed the actual cost of care. In the model, such a program can get more than its cost, up to the center rate, and no test checks a group payment against the program's cost.
  • The 35% combined limit applies to every district from December 24, 2025. The figure comes from the State Register's summary of the proposed rule, which OCFS adopted with no changes, and neither notice prints the amended text. In the proposal, OCFS says districts must amend their plans for a change in the maximum. Monroe County's plan states 25% and requests no waiver, and the model pays Monroe County's 30% in January 2026 without an amendment.
  • Monthly calculations read each dated value on the first day of the month. Monroe County's rates, approved effective November 18, 2024, first apply in December 2024, and the 35% limit first applies in January 2026.
  • New York City's 15% nontraditional rate comes from September 2023 City Council testimony that gives no start date, and the model applies it from October 1, 2024. FS-023 lists no differential, so the city's homelessness and accreditation rates follow the state defaults.
  • Every district other than New York City and Monroe County pays the state defaults. Those defaults pay the minimum for the two mandatory differentials, nothing for the two optional ones, standard legally exempt group rates and the 70% enhanced informal rate.
  • A nontraditional-hours input applies that differential to the child's whole monthly payment, since the model's inputs don't split care by hour. Districts pay it on care during those hours.
  • is_disabled stands in for the district's special-needs determination under 415.1(c), with a separate input for the parent's showing. The model compares the regular rate with the child's equal share of the family's expenses.
  • An OCFS waiver enters through the combined-limit parameter, and the model has no waiver by default.
• Gates checked live at merge:
  • gh pr checks exits 0;
  • the latest Pull request run at the head, 43654879593, passed and tested this head merged into main at 7c516c74bb;
  • MERGEABLE;
  • not a draft;
  • no reviewer's latest review requests changes;
  • the semantic-overlap guard: since 7c516c74bb, main has changed no area this PR touches. Between the PR's merge base 3ab9b19a11 and main at 7c516c74bb, main changed one file this PR touches, programs.yaml, where it edited the South Dakota CCA notes in Pay South Dakota CCA from the July 2024 hourly county rates #10815 and this PR edits the New York CCAP notes. Main changed nothing under ny/ocfs. Count gambling winnings in federal gross income and fix the wagering losses deduction #10070 changed New York's itemized deduction files, which this PR does not touch, and none of this PR's 13 changed variable files reads a variable that Count gambling winnings in federal gross income and fix the wagering losses deduction #10070 changed. Count public assistance and SSI supplements in New York CCAP income #10827, which also changes New York CCAP, hasn't landed. It conflicts with this PR in programs.yaml, so whichever of the two lands second merges main first. The branch merges into main at 7c516c74bb without conflict;
  • the merge pins the head.
• Impact: we estimate no change in 2026 on the default dataset, where New York's child care subsidy totals $0 on both sides. None of the seven measured outputs moves between main 3ab9b19a11 and d7c1548c2e.
• Next:
  • The model lets a differential lift the payment to a legally exempt group program with an enhanced rate above the program's cost, past the limit in 415.9(g)(7). I drafted an issue to file at landing: confirm the paragraph in the current Part 415, add the limit, and record the difference from LCM-22 as a source conflict.
  • Monroe County chose a 75% enhanced informal rate on PDF page 105 of its plan, and the model keeps group 2's 70% cells there. I drafted an issue for a Monroe County override of those cells, to file at landing.
  • If this PR lands first, Count public assistance and SSI supplements in New York CCAP income #10827 conflicts with main in the New York CCAP notes of programs.yaml. Whoever merges main into Count public assistance and SSI supplements in New York CCAP income #10827 should keep this PR's sentences on differentials, the special-needs rate and New York City's rates, and leave out of "Not modeled" the items either PR removes. If Count public assistance and SSI supplements in New York CCAP income #10827 lands first, this PR merges main the same way and keeps Count public assistance and SSI supplements in New York CCAP income #10827's sentence on countable income.
  • OCFS's December 24, 2025 rule adds optional 5% to 15% differentials for providers in QUALITYstarsNY and the auto-injector initiative. An issue can add an input and a district rate for each, with 0% by default.
  • ACS publishes no differential schedule in FS-023. An issue can find the city's homelessness and accreditation rates and the start date of its 15% nontraditional rate.
  • Neither State Register notice prints the amended 415.9. A reader with browser access to OCFS's current Part 415 can check the 10% minimums, the 35% limit and paragraph (g)(7) against its text.
  • Eleven variable files and eight parameter files in this PR cite 18 NYCRR 415.9 at law.cornell.edu. An issue can move every New York CCAP reference to OCFS's Part 415 compilation, where 415.9 starts on PDF page 44.
• Axiom: Encode New York child care assistance payment rates: differentials, the special-needs rate, legally exempt group limits and New York City's enhanced rates (Social Services Law § 410-x(10); 18 NYCRR 415.9; 24-OCFS-LCM-22) (PE-US #10821) TheAxiomFoundation/rulespec-us#2244 queued, a new pe-parity issue for Social Services Law 410-x(10), 18 NYCRR 415.9(f), (g) and (h), and 24-OCFS-LCM-22 pages 7 to 10, with companion rows from this PR's YAML. The signed encoder can't run yet: the corpus holds no section 410-x, no OCFS Part 415, no LCM-22 and neither 2025 State Register issue.

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