Include incapacitated adult care expenses in state TANF dependent care deductions

[hua7450]

Summary

Adds the person-level care_expenses input (care for a disabled/incapacitated adult) to the dependent care deductions of 21 state TANF-family cash assistance programs (23 variables) that previously only counted childcare_expenses. Where the regulation includes incapacitated adults in the per-person cap, they are added to the cap population; where the cap side already included them (TX, VA) only the expense side changes. MT's cap side previously also required the incapacitated adult to be a tax dependent — Mont. Admin. r. 37.78.406(2)(c) imposes no dependency requirement, so this PR drops it (an incapacitated spouse now qualifies; test Case 7 flips 0 → $200).

Closes #8811 (together with #8980 for SNAP and #8981 for TX FPP / HI CDCC / MT tax deduction).

Verification

Every program was verified against its statute or policy manual (verbatim quotes checked against primary sources) before editing:

Program	Authority	Adult-care rule	Adult cap
AK ATAP	7 AAC 45.485(a)(2)(C)	incapacitated parent whose needs are in the AU (only)	$175/mo
AL Family Assistance	Ala. Admin. Code r. 660-2-2-.30(2)(c)	"child care or care for an incapacitated adult living in the same home and receiving FA"	none (actual cost)
AZ Cash Assistance	ARS 46-292(P)(1)	"care of an adult or child dependent household member"	$175/mo
DC TANF	DC Code § 4-205.11(a)(2) + ESA Policy Manual	"incapacitated adult living in the same home and receiving TANF or POWER"	$175/mo
DE TANF	DSSM 4004.2(4)	"$175/mo per dependent child or incapacitated adult"	$175/mo
GA TANF	PAMMS 1615	"care of an incapacitated individual in the home"; "$175 monthly for each individual age two or above"	$175/mo
HI TANF	State Plan § 10.2.1(D)	"cost of care for a disabled adult household member"	$175 FT / $165 PT
IL TANF	89 Ill. Adm. Code 112.143(b)(1)(C)	"care of an incapacitated adult" is an exception to direct payment, using the care deduction	$175/mo (age-2+ tier)
KY K-TAP	921 KAR 2:016 § 5(3)(b)1.b	"incapacitated adult living in the home and receiving KTAP"	$175 FT / $150 PT (PT not modeled, pre-existing)
MA TAFDC + EAEDC	106 CMR 704.275(A)	"$175 per dependent child, age two or older, or incapacitated individual"	$175/mo (hours-proportional)
MD TCA	COMAR 07.03.03.13.E(3)(c)	"each child in the assistance unit or an incapacitated adult living in the home"	$200 (100+ hrs/mo) / $100
ME TANF	10-144 CMR ch. 331, Ch. IV § B(2)(b)	"each dependent child or incapacitated adult needing care" (manual extends the child-only statute)	$175/mo
MN MFIP	Combined Manual § 0018.09	"care for a minor child or disabled adult in the unit" (applicant eligibility test only — matches existing model)	manual states no adult cap; $175 tier applied
MO Temporary Assistance	13 CSR 40-2.120(6)(A)5	"an incapacitated individual living in the same home as the dependent child, receiving AFDC"	$175/mo
MT TANF	TANF Manual 602-1	"each minor child or incapacitated adult" (cap side already modeled; this PR drops its extra tax-dependency requirement per Mont. Admin. r. 37.78.406(2)(c))	$200/mo
NH FANF	FAM 603.05	"dependent child or incapacitated parent" (only)	$175 FT / $87.50 PT
OK TANF	OAC 340:10-3-33(b)(3)(B)	"$175 for a dependent two years of age and older or for an incapacitated adult"	$175/mo
RI Works	218-RICR-20-00-2.15.5(B)(2)	"each dependent child or incapacitated adult living in the home and receiving cash assistance"	$175/mo
TX TANF	1 TAC § 372.409(a)(3)	"$175 monthly for each dependent child age two or older (or incapacitated adult)" (cap side already modeled)	$175/mo
VA TANF	TANF Manual § 305.3 item 5	"Incapacitated Adult/Child Care Disregard" (cap side already modeled)	$175 FT ($120 PT not modeled, pre-existing)
VT Reach Up	Rule 2252.2(a)	"care for a household member who is a disabled or seriously ill adult"	$175/mo per participant
WV Works	IMM § 4.5.2.A.2	"dependent child or incapacitated adult care"	none

Verified child-only — deliberately unchanged

• NM Works — 8.102.520.12(D) NMAC says "child" exclusively.
• IL AABD — 89 Ill. Adm. Code 113.125(b) is titled "Child Care" with per-child caps only.
• TN Families First — 1240-1-50-.16(1)(c)5(ii) says "child/dependent" and never mentions incapacitated adults; treated as not established.

Modeling notes

• "Incapacitated adult" is modeled as is_adult & is_incapable_of_self_care (or is_disabled where the state's operative word is "disabled": HI, MN); "incapacitated parent" (AK, NH) as is_tax_unit_head_or_spouse & is_incapable_of_self_care. VA's manual keys on incapacity ("Incapacitated Adult/Child Care Disregard"), so its pre-existing is_disabled mask was switched to is_incapable_of_self_care.
• Live-in / receiving-assistance conditions on the cared-for adult (e.g., "receiving TANF") are approximated by SPM unit membership, consistent with how the child side is modeled.
• Reference URL fixes: DE now cites DSSM 4004.2 (the operative disregard section, not 4008), MD cites the current COMAR source (old dsd.maryland.gov is dead), VA and WV point at the current manuals (old links 404).

Impact

care_expenses defaults to 0, so all existing tests, partner contract tests, and microsimulation results are unchanged unless the input is supplied.

Test plan

• One new test case per program (23 cases) — each chosen so the old and new formulas produce different values (e.g., adult-care-only household: 0 before, 100/month after)
• Negative population-filter test per capped program (adult without the qualifying condition adds nothing to the cap), incl. incapacitated non-parent cases for AK/NH and a non-dependent adult for AZ
• KY/MO above-cap adult cases pinning the $175 age-2+ tier targeted by the cap_age remap
• CI passes

🤖 Generated with Claude Code

[daphnehanse11]

Program review (automated multi-agent)

Scope

Reviewed all 23 changed variable files, 24 test files, and the changelog fragment in PR #8982 (incapacitated adult care expenses in state TANF dependent care deductions, 22 states). Four regulatory auditors verified every state against primary sources (statutes, admin codes, and 6 PDF manuals), plus a reference validator, code-pattern validator, test-coverage analyst, and two follow-up verifiers. CI is fully green (all suites + changelog check).

Regulatory verification — 22/22 states verified

State	Authority verified	Verdict	Note
AK	7 AAC 45.485(a)(2)(C)	Verified	Parent-only mask correct; $175 tier
AL	Ala. Admin. Code r. 660-2-2-.30(2)(c)	Verified	Uncapped, as-paid; correct
AZ	ARS 46-292(P)(1)	Verified	Dependency (not incapacity) required; matches
DC	DC Code § 4-205.11(a)(2); ESA manual p.297	Verified	Any incapacitated adult; $175
DE	DSSM 4004.2(4) (4000.pdf#page=6)	Verified	$175; new reference URL lands on value
GA	PAMMS 1615	Verified	Cap wording "individual" supports adults
HI	State Plan §10.2.1(D) (p.20)	Verified	"Disabled" wording; $175 FT / $165 PT
IL (TANF)	89 Ill. Adm. Code 112.143(b)(1)(C)	Verified, caveat	Weakest statutory footing — see Should #2
KY	921 KAR 2:016 §5(3)(b)	Verified	Age-13 zero-out remap correct, test-pinned
MA TAFDC	106 CMR 704.275(A)	Verified	$175 older tier, hours-based
MA EAEDC	106 CMR 704.275(A) (shared)	Verified	Same param/section reuse pre-existing
MD	COMAR 07.03.03.13.E(3)(c)	Verified	$200/$100 hours tiers match
ME	10-144 CMR ch. 331 IV §B(2)(b)	Verified	Manual extends child-only statute, as PR claims
MN	Combined Manual §0018.09 (file p.594)	Verified	$175 adult cap is a disclosed conservative approx
MO	13 CSR 40-2.120(6)(A)5	Verified	Age-18 zero-out remap correct, test-pinned
MT	TANF Manual 602-1	Verified	$200 cap; mask broadening reg-supported
NH	FAM 603.05	Verified	Incapacitated parent only; matches
OK	OAC 340:10-3-33(3)(B)	Verified	$175 for incapacitated adult
RI	218-RICR-20-00-2.15.5(B)(2)	Verified	$175; live-in/receiving approximated
TX	1 TAC 372.409(a)(3)	Verified	Expense side only; cap pre-existing
VA	Manual §305.3 item 5 (#page=175)	Verified	Incapacity is the operative key; retrofits safe
VT	Reach Up Rule 2252.2(a),(c) (p.74)	Verified	$175 per participant cap
WV	IMM §4.5.2.A.2 (#page=590)	Verified	Uncapped disregard explicitly confirmed
NM (unchanged)	8.102.520.12(D) NMAC	Verified child-only	Correctly left unchanged
IL AABD (unchanged)	89 Ill. Adm. Code 113.125(b)	Verified child-only	Correctly left unchanged
TN (unchanged)	1240-01-50	Source unreachable	No code change = no risk; re-check later

Critical (must fix)

None.

Should address

1. MT: PR description mischaracterizes the change. The PR body says MT's "cap side already included them (only the expense side changes)," but policyengine_us/variables/gov/states/mt/dphhs/tanf/income/deductions/mt_tanf_dependent_care_deduction.py (lines 27–29) rewrites the cap mask from is_dependent & (is_child | is_incapable_of_self_care) to (is_dependent & is_child) | (is_adult & is_incapable_of_self_care), dropping the dependency requirement for adults — test Case 7 flips 0 → 200. The broadening is regulation-supported (Mont. Admin. r. 37.78.406(2)(c); manual 602-1 states no dependency requirement), so this is a documentation fix: update the PR body/table to disclose the MT cap-side change (as was done for VA).
2. IL TANF: confirm the statutory footing for the adult deduction cap. In 89 Ill. Adm. Code 112.143, the operative cap in (b)(2) is worded "per child," and (b)(1)(C) ("For the care of an incapacitated adult") reads as an exception to direct payment rather than an explicit adult deduction cap. The PR body concedes this framing; the ILGA source did not render §112.143 (Cornell text used). Inclusion is defensible but this is the weakest statutory basis in the PR — a maintainer should confirm before merge. File: policyengine_us/variables/gov/states/il/dhs/tanf/il_tanf_countable_earned_income.py (deduction variable).
3. Adult $175-vs-$200 tier unpinned in most age-based states. Positive tests for AK, AZ, DC, DE, GA, IL, OK, RI, TX, MN, HI, MD, ME use expenses of $100/mo — below every tier — so a schedule that wrongly gave the adult the $200 (<2) tier would still pass. Only KY/MO/MT pin the adult cap with above-cap expenses. Add one above-cap adult case (e.g. expenses 3_600/yr → expect 175) to a representative subset of the age-based states as a regression guard.
4. Combined child + incapacitated-adult cap interaction tested only in MT. The summed per-person cap with pooled numerator (childcare_expenses + care_expenses) is the most bug-prone interaction. Add one combined case for a representative age-based summed-cap state (e.g. DC, IL, or RI).
5. AL/WV/VT apply no per-recipient incapacity filter in-formula, relying on care_expenses' input semantics ("disabled adult dependent or spouse"), so the incapacity flags in those tests are cosmetic. Defensible and acknowledged in diff comments, but note the modeling gap explicitly in each variable's docstring (files: al_..._countable_earned_income.py, wv_works_countable_earned_income.py, vt_reach_up_..._deduction.py).

Suggestions

1. Changelog fragment changelog.d/tanf-adult-care-expenses.changed.md says "21 state ... programs" but the PR covers 22 state groups / 23 variables — reconcile the count.
2. TX uses bare is_incapable_of_self_care (no is_adult &) in tx_tanf_dependent_care_deduction.py:27,31, diverging from the convention every other capped state follows. Pre-existing and negligible in impact, but easy to align.
3. Capped states pool all care_expenses on the expense side regardless of the qualifying-population mask, so an ineligible person's care expense can consume another member's cap room (e.g. AZ non-dependent adult). Symmetric with existing childcare behavior and bounded by the cap; could scope the expense side to qualifying recipients for tighter fidelity.
4. Unmodeled pre-existing conditions, all approximated by SPM-unit membership consistent with the child side: physician verification and employment nexus (GA), FT/PT keyed to applicant vs unit-max hours (HI, MA), in-home/provider-identity bars (ME, MT, VT), "same home as the dependent child" (MO), live-in/"receiving assistance" requirements generally.
5. Test hygiene: GA/KY/MO/OK new cases drop the Case N, … naming convention; WV Case 6 lists absolute_error_margin before period; consider a note/test locking the dependent-child-with-care_expenses double-count behavior (esp. ME, which special-cases disabled children).
6. VA: the $175 full-time value is corroborated in Appendix 3 to §305, not on the referenced page 175 itself (which carries the rule text) — optionally add the appendix page.
7. TN: re-verify 1240-01-50 ("child/dependent only" reading) when tnsosfiles.com is reachable; no code depends on it today.
8. Most modified variables cite the new incapacitated-adult authority only in code comments with no class-level reference = attribute — matches the pre-existing convention in those files, not a regression.
9. Minor period-arg style inconsistencies on YEAR booleans (VA is_adult at period; AZ is_tax_unit_dependent at period.this_year) — results unaffected.

Investigated and cleared

• WV #page=590: initially unreachable to the reference validator (24.6 MB PDF over fetch cap); follow-up download + pdftotext confirmed IMM §4.5.2.A.2 (Dependent Care Deduction) is on file page 590 and that the manual explicitly states "There is not a maximum allowable amount" — the uncapped modeling is correct.
• MN adult cap: manual §0018.09 states the $200/$175 caps only for child care; code applies the $175 tier to the disabled adult. Conservative (under-counts above $175) and disclosed in the PR — acceptable approximation.
• VA test retrofits: the is_disabled → is_incapable_of_self_care renames in unit tests and integration.yaml preserve all prior expected outputs; no silent behavior change.
• care_expenses: confirmed a pre-existing Person-level YEAR input (policyengine_us/variables/household/expense/childcare/care_expenses.py); no variable was reinvented, and person→SPM-unit aggregation with YEAR→MONTH ÷12 is correct (tests use 1,200/yr → 100/mo).
• Period handling: verified clean across all 23 variable files — period.this_year/monthly_age for ages, YEAR dollar flows auto-converted at MONTH consistently on expense and cap sides.
• References: all 5 changed/added reference URLs (DE, MD, VA, ME, WV) verified correct against page-level content.
• Deliberately unchanged programs: NM (8.102.520.12(D) NMAC) and IL AABD (89 Ill. Adm. Code 113.125(b)) confirmed child-only; leaving them unchanged is correct.

Validation summary

Check	Result
Regulatory accuracy	22/22 states verified against primary sources; 0 mismatches
Reference quality	5/5 changed/added URLs verified correct
Code patterns	0 critical; period handling, vectorization, no hard-coding all clean
Test coverage	0 critical; 3 should-level gaps (tier pinning, combined-cap case, docstring notes)
Changelog fragment	Present, correct type; count wording off by one (suggestion)
CI	Passing (all suites + changelog check)

Review severity: COMMENT

No blocking issues; the should-address items are PR-description accuracy (MT), one statutory-footing confirmation (IL), and test hardening.

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Automated review: 4 regulatory auditors (primary-source verification incl. 6 PDF manuals), reference validator, code-pattern validator, test-coverage analyst, plus follow-up verifiers. Read-only; no code changed.

[daphnehanse11]

Approving based on the multi-agent review above: 22/22 states verified against primary sources with no regulatory or value mismatches, references confirmed, code patterns and period handling clean, CI green. Remaining items (PR-description accuracy for MT, test hardening) are non-blocking.