Count public assistance and SSI supplements in New York CCAP income

changelog.d/ny-ccap-public-assistance-income.added.md

@@ -0,0 +1 @@
+Counted Family Assistance, Safety Net Assistance payments and adult state SSI supplements in New York child care assistance income, and waived the family share for families that take up Family Assistance.

changelog.d/ny-ccap-public-assistance-income.fixed.md

@@ -0,0 +1 @@
+Counted New York children's SSI and state supplements in child care assistance income before October 1, 2023, when OCFS began excluding them.

policyengine_us/parameters/gov/states/ny/ocfs/ccap/income/countable_income/child_ssi_exclusion_in_effect.yaml

@@ -0,0 +1,22 @@
+description: New York excludes the SSI and state supplemental payments of children in the child care services unit from Child Care Assistance Program income if this is true.
+# Before October 1, 2023, OCFS counted SSI, including State supplemental
+# payments, for every member of the unit under 404.5(b)(5)(vi). OCFS added
+# the child exclusion from October 1, 2023 through emergency rule
+# CFS-42-23-00002-EP and adopted it permanently on June 12, 2024.
+values:
+  2021-10-01: false
+  2023-10-01: true
+
+metadata:
+  unit: bool
+  period: month
+  label: New York CCAP child SSI exclusion in effect
+  reference:
+    - title: 18 NYCRR 404.5(b)(5)(vi), OCFS compilation current as of November 24, 2021
+      href: https://web.archive.org/web/20220529152858id_/https://ocfs.ny.gov/programs/childcare/regulations/404-Eligibility.pdf#page=10
+    - title: NYS Register, October 18, 2023, CFS-42-23-00002-EP, effective October 1, 2023
+      href: https://dos.ny.gov/system/files/documents/2023/10/101823.pdf#page=7
+    - title: "18 NYCRR 404.5(b)(5)(vi) and (b)(6)(xxi), OCFS compilation current as of October 1, 2023 #page 10,12"
+      href: https://web.archive.org/web/20240522174247id_/https://ocfs.ny.gov/programs/childcare/regulations/404-Eligibility.pdf#page=10
+    - title: NYS Register, June 12, 2024, CFS-42-23-00002-A, permanent adoption effective June 12, 2024
+      href: https://dos.ny.gov/system/files/documents/2024/06/061224.pdf#page=7

policyengine_us/parameters/gov/states/ny/ocfs/ccap/income/countable_income/sources.yaml

@@ -23,6 +23,8 @@ values:
     - dividend_income
     - interest_income
     - rental_income
+    # 404.5(b)(5)(vi): public assistance, including home relief.
+    - ny_safety_net_assistance
     # 404.5(b)(5)(vii): pensions and annuities. PolicyEngine records military
     # retirement separately from pension_income.
     - pension_income
@@ -37,10 +39,14 @@ values:
     # 404.5(b)(5)(xii): veterans' pensions.
     - veterans_benefits
     #
-    # Counted but not listed here because the amount depends on who receives
-    # it — see ny_ccap_countable_income:
-    # - ssi, countable in full under 404.5(b)(5)(vi) except for the SSI of any
-    #   child in the child care services unit, which 404.5(b)(6)(xxi) excludes.
+    # Counted separately in ny_ccap_countable_income:
+    # - ny_ccap_family_assistance, the ny_tanf grant the family takes up.
+    #   The New York grant avoids other states' dependent care deductions in
+    #   the federal TANF aggregate, which reach CCAP through child care
+    #   subsidies.
+    # - ssi and ny_ssp under 404.5(b)(5)(vi). From October 1, 2023, OCFS
+    #   excludes both payments for children in the unit under
+    #   404.5(b)(6)(xxi); see child_ssi_exclusion_in_effect.
     #
     # Excluded sources, so simply not listed:
     # - capital_gains, excluded by 404.5(b)(6)(viii), and proceeds from the
@@ -53,17 +59,6 @@ values:
     #   and 404.5(b)(5) is a closed enumeration.
     # - gi_cash_assistance, illicit_income and miscellaneous_income, none of
     #   which appear in the 404.5(b)(5) enumeration.
-    # - tanf and other public assistance. These are countable under
-    #   404.5(b)(5)(vi), but counting them closes a circular dependency:
-    #   ny_ccap_countable_income -> tanf -> childcare_expenses ->
-    #   child_care_subsidies -> ny_ccap -> ny_ccap_countable_income. The same
-    #   hazard is documented in
-    #   gov/states/in/fssa/ccdf/income/sources.yaml. Omitting them understates
-    #   countable income for public-assistance households, which is partly
-    #   offset because 415.3(e)(1) exempts those households from the family
-    #   share entirely.
-    # - state supplementary payments to SSI recipients, countable under
-    #   404.5(b)(5)(vi). PolicyEngine has no state supplement variable.
 
 metadata:
   unit: list

policyengine_us/programs.yaml

@@ -875,7 +875,7 @@ programs:
         full_name: New York Child Care Assistance Program
         variable: ny_ccap
         parameter_prefix: gov.states.ny.ocfs.ccap
-        notes: PolicyEngine models New York income eligibility, market rates, payment differentials, the special-needs rate, New York City enhanced informal and group rates, and the family share. It includes the categorical routes for foster care, protective services and preventive care with district approval under Title XX. It applies public assistance activity conditions and the 18 NYCRR 415.1(b) age extensions for special needs and court supervision. It also applies the statutory family share exceptions for public assistance, preventive care and child-only units. The model prices excess periods for a sixth or seventh day of care, and for each day of care at or above the daily maximum hours, at the applicable daily or part-day rate under 24-OCFS-LCM-22. Without a county or county FIPS input, the model places a New York household in Albany County, in county group 2. That placement overstates rates for households in the 38 group 3 counties and understates them in New York City and the five group 1 counties. An UNKNOWN county falls to group 3, the lowest-rate group. The benefit requires childcare_hours_per_day and childcare_days_per_week as well as expenses, because OCFS sets market rates by duration of care; expenses alone yield no benefit. OCFS dropped hourly market rates on June 1, 2022 (22-OCFS-LCM-14); 18 NYCRR 415.9 and 24-OCFS-LCM-22 set weekly, daily and part-day rates only. Outside its New York City and Monroe County rates, the model uses state defaults for district choices, with the minimum for mandatory differentials (5%, then 10% from April 1, 2025, under Social Services Law 410-x(10)) and zero for optional ones. The combined limit rises from 25% to 35% on December 24, 2025. Not modeled - the optional differentials for QUALITYstarsNY and the auto-injector initiative that OCFS added on December 24, 2025, Monroe County's 75% enhanced informal rate, and public assistance in countable income (omitted to avoid a circular dependency through the TANF dependent care deduction)
+        notes: PolicyEngine models New York income eligibility, market rates, payment differentials, the special-needs rate, New York City enhanced informal and group rates, and the family share. It counts Family Assistance, Safety Net Assistance payments and SSI state supplements in income, and children's SSI and supplements only before October 1, 2023. It includes the categorical routes for foster care, protective services and preventive care with district approval under Title XX. It applies public assistance activity conditions and the 18 NYCRR 415.1(b) age extensions for special needs and court supervision. It also applies the statutory family share exceptions for public assistance, preventive care and child-only units. The model prices excess periods for a sixth or seventh day of care, and for each day of care at or above the daily maximum hours, at the applicable daily or part-day rate under 24-OCFS-LCM-22. Without a county or county FIPS input, the model places a New York household in Albany County, in county group 2. That placement overstates rates for households in the 38 group 3 counties and understates them in New York City and the five group 1 counties. An UNKNOWN county falls to group 3, the lowest-rate group. The benefit requires childcare_hours_per_day and childcare_days_per_week as well as expenses, because OCFS sets market rates by duration of care; expenses alone yield no benefit. OCFS dropped hourly market rates on June 1, 2022 (22-OCFS-LCM-14); 18 NYCRR 415.9 and 24-OCFS-LCM-22 set weekly, daily and part-day rates only. Outside its New York City and Monroe County rates, the model uses state defaults for district choices, with the minimum for mandatory differentials (5%, then 10% from April 1, 2025, under Social Services Law 410-x(10)) and zero for optional ones. The combined limit rises from 25% to 35% on December 24, 2025. Not modeled - the optional differentials for QUALITYstarsNY and the auto-injector initiative that OCFS added on December 24, 2025, and Monroe County's 75% enhanced informal rate
       - state: OR
         status: complete
         name: Oregon ERDC

policyengine_us/tests/core/test_ny_ccap_categorical_routes_invariants.py

@@ -121,6 +121,10 @@ def _situation(cases, year):
         unit = {
             "members": members,
             "is_tanf_enrolled": {month: family["tanf"]},
+            # These families enter no earnings, so PolicyEngine would compute
+            # a Family Assistance grant and waive the share. Set the grant to
+            # zero, so only reported enrollment marks Family Assistance receipt.
+            "ny_tanf": {month: 0},
             "meets_ccdf_activity_test": {year: family["fallback"]},
             "ny_ccap_countable_income": {year: 12 * family["income"]},
             "spm_unit_fpg": {year: 12 * family["fpg"]},