Count general assistance as unearned income in TANF, WIC, and school meals lists

[hua7450]

Summary

Adds general_assistance (agency cash aid such as general relief, BIA General Assistance, or refugee cash assistance) to the income-source lists whose authority counts public assistance payments, gives Maine TANF its own unearned list because its manual excludes General Assistance, and documents the other state TANF lists whose manuals exclude it or do not name it.

Closes #9382

Companion to #9383 (Texas TANF list), which already adds general_assistance to the Texas list.

Changes

List	Change	Authority
gov/usda/wic/income/sources.yaml	Added; file reference widened to the full income definition	7 CFR 246.7(d)(2)(ii)(E): income includes "public assistance or welfare payments"
gov/usda/school_meals/income/sources.yaml	Added, plus reference	7 CFR 245.6(a)(5)(ii) lists welfare among the sources of cash income
DC dc/dhs/tanf/income/sources/unearned.yaml	Added	D.C. Code § 4-205.05(4): "income" includes "District public assistance payments; federal public assistance payments"
IL il/dhs/tanf/income/sources/unearned.yaml	Added	89 Ill. Adm. Code 112.100(c): unearned income includes "need based payments, cash assistance"
MT mt/dhs/tanf/income/sources/unearned.yaml	Added; general_assistance is a proxy for BIA General Assistance since Montana has no broad state GA program	TANF 501-1, Assistance Programs: "Bureau of Indian Affairs (BIA) General Assistance; countable"
ME new me/dhhs/tanf/income/sources/unearned.yaml + me_tanf_gross_unearned_income	New state list, item for item the federal baseline Maine already consumed, so Maine's output is unchanged; me_tanf_countable_unearned_income now reads it and the list documents the GA exclusion	10-144 CMR ch. 331, Ch. III § B(2)(d) excludes "General Assistance, Emergency Assistance, HUD, FMHA utility reimbursements and other supplemental assistance from public or private agencies to help the assistance unit meet their basic needs"
CO co/cdhs/tanf/income/unearned.yaml	Comment plus a § 3.605.4 reference	9 CCR 2503-6 § 3.605.4(A)(7) exempts "General Assistance granted to a client by the county department"
NC nc/ncdhhs/tanf/income/unearned.yaml	Comment only	WF-114 income chart: "General Assistance (GA) Payments — No"
financial_assistance documentation	"Cash financial assistance from friends or relatives outside the household."	Matches the CPS FIN_VAL source so partners do not map agency aid to it

Not changed

• Federal TANF baseline gov/hhs/tanf/cash/income/sources/unearned.yaml: left unchanged. A state-by-state audit of the 42 inheriting states found 10 that exclude general assistance or a named GA program (AZ, AR, GA, IN, ME, MI, NE, OR, RI, VT), about 14 that count it only after a need-standard gap or duplication test, 4 unresolved (CT, ID, NY, WV), and only 3 that name it as countable (MN, ND, WY, tracked in Count general_assistance as TANF unearned income in Minnesota, North Dakota, and Wyoming #9390). See the audit summary in the comments.
• SC sc/tanf/income/unearned.yaml: § 7.1 defines unearned income as anything not earned, but the § 7.7 income chart (volumes 65 and 66) has no general assistance entry, so there is no explicit support; left as is.
• MA TCAP list (ma/dta/tcap/gross_income/unearned.yaml): 106 CMR 704.210(B) enumerates specific sources and does not name general assistance, and 704.250(CC) excludes non-duplicating agency assistance; left as is.
• CA CalWORKs lists: narrow enumerations with no public assistance entry; left as is.
• gi_cash_assistance in SNAP: out of scope per Count general_assistance as unearned income in TANF, WIC, and school meals income lists #9382.
• Observation for a separate issue: D.C. Code § 4-205.05(4) excludes "direct cash assistance payments received from District-based cash assistance programs or pilot programs ... administered by a nonprofit organization", which suggests gi_cash_assistance may not belong in the DC list.

All list additions are inert for microsimulation because the CPS dataset never populates general_assistance; only API callers that send it are affected.

Tests

• New: il_tanf_gross_unearned_income.yaml, me_tanf_gross_unearned_income.yaml
• Extended: wic_countable_income.yaml, school_meal_countable_income.yaml, dc_tanf_countable_unearned_income.yaml, mt_tanf_gross_unearned_income.yaml (each with a general-assistance-present case and a general-assistance-absent control), Maine integration.yaml (Case 1 with $2,400/year general assistance still pays $895)

Test plan

• CI passes

🤖 Generated with Claude Code

[codecov]

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 100.00%. Comparing base (af33835) to head (e21799b).
⚠️ Report is 17 commits behind head on main.

Additional details and impacted files

@@            Coverage Diff            @@
##              main     #9384   +/-   ##
=========================================
  Coverage   100.00%   100.00%           
=========================================
  Files            2         3    +1     
  Lines           36        33    -3     
=========================================
- Hits            36        33    -3     

Flag	Coverage Δ
unittests	100.00% <100.00%> (ø)

Flags with carried forward coverage won't be shown. Click here to find out more.

☔ View full report in Codecov by Harness.
📢 Have feedback on the report? Share it here.

🚀 New features to boost your workflow:

• ❄️ Test Analytics: Detect flaky tests, report on failures, and find test suite problems.

[hua7450]

Audit of the 42 states inheriting the federal TANF unearned list

Why the shared baseline gov/hhs/tanf/cash/income/sources/unearned.yaml does not get general_assistance in this PR. Each row is the state manual's treatment of General Assistance or comparable agency cash aid for TANF countable income.

Result	States
Excluded, GA or a named GA program	Arizona (BIA GA), Arkansas (needs-based agency aid), Georgia (county GA), Indiana (township assistance), Maine (GA, Ch. III B(2)(d)), Michigan (SDA), Nebraska, Oregon, Rhode Island (other-agency aid), Vermont
Conditional: need-standard gap, duplication test, or program identity	Alabama, Florida, Hawaii, Iowa, Kentucky, Missouri (General Relief excluded, RCA included), Nevada, New Jersey, Oklahoma, Pennsylvania, South Dakota, Virginia, Washington, Wisconsin
Unresolved by the public rule	Connecticut, Idaho, New York, West Virginia
Counts, GA named explicitly	Minnesota (GA and RCA), North Dakota, Wyoming — follow-up in #9390
Counts, broad-rule inference only	Alaska, Delaware, Kansas, Louisiana, Maryland, Mississippi, New Hampshire, New Mexico, Ohio, Tennessee, Utah

Only the last two groups would be served by a baseline entry, and the first three would be modeled wrongly by it. Conditional states need formula logic, not a list entry.

[DTrim99]

Program Review — PR #9384 (general assistance as unearned income)

Scope

• Multi-program: DC/IL/MT TANF (GA now counted), CO/NC TANF (comment-only), USDA WIC + school meals (GA counted), new ME gross-unearned list (excludes GA, uses financial_assistance) + me_tanf rewire.
• Source: regulatory HTML citations (no dollar-table PDF).

Critical (Must Fix)

1. WIC — general_assistance entry cites the wrong subsection.
   • File: policyengine_us/parameters/gov/usda/wic/income/sources.yaml (added list entry + inline comment; reference block).
   • The added comment reads # 7 CFR 246.7(d)(2)(ii)(A) counts public assistance or welfare payments. and the entry's reference points at 7 CFR 246.7(d)(2)(ii)(A) (title/href both anchor #d_2_ii_A). Verified against 7 CFR 246.7(d)(2)(ii): subsection (A) is "Monetary compensation for services, including wages, salary, commissions, or fees" — it does not cover public assistance/welfare. "Public assistance or welfare payments" is subsection (E).
   • This is a citation-precision defect, not a value error: counting general assistance for WIC is correct (GA is countable income under 246.7(d)(2)(ii)(E)). The clicked (A) anchor simply does not show the provision that makes GA countable.
   • Correct citation: 7 CFR 246.7(d)(2)(ii)(E). Fix the inline comment and add an (E) reference. Keep the existing (A) reference (it also serves as the file's umbrella cite for wages).

Should Address

1. WIC file-level reference is too narrow for the whole list.

   • File: policyengine_us/parameters/gov/usda/wic/income/sources.yaml (metadata.reference).
   • The single reference 7 CFR 246.7(d)(2)(ii)(A) is used to justify ~20 disparate sources (interest, pension, survivor benefits, etc.), but (A) only covers monetary compensation for services. Pre-existing weakness surfaced by the new entry. Recommend citing the full 7 CFR 246.7(d)(2)(ii) definition (list (A)–(M)) rather than only (A).

2. School-meals citation points to 7 CFR 245.6(a)(5); the list of income sources is actually at (a)(5)(ii).

   • File: policyengine_us/parameters/gov/usda/school_meals/income/sources.yaml (added comment + reference title: ... 7 CFR 245.6(a)(5) / href #a_5).
   • Substantive treatment is correct — 7 CFR 245.6(a)(5)(ii) lists "welfare" among the cash income sources, so counting general_assistance is right. Tighten the comment and reference anchor to (a)(5)(ii) for accuracy.

3. Montana counts only BIA General Assistance, but the model adds the generic general_assistance.

   • File: policyengine_us/parameters/gov/states/mt/dhs/tanf/income/sources/unearned.yaml (added - general_assistance; comment # TANF 501-1 counts Bureau of Indian Affairs General Assistance).
   • Verified from MT TANF 501-1 ("Assistance Programs" item 4): only BIA General Assistance is countable (SSI and State Supplemental Payments excluded). The model's general_assistance is a generic person-level input covering any GA, so the list entry counts all GA, not only BIA GA. In practice Montana has no broad state GA program, and there is no BIA-specific input to map to, so using the generic variable as a BIA proxy is a defensible approximation. Recommend the comment state explicitly that the generic variable is a proxy for BIA GA, so the scope mismatch is documented rather than implied. Cite Mont. TANF 501-1; Mont. Admin. r. 37.78.402.

4. NC comment page number vs. reference anchor mismatch.

   • File: policyengine_us/parameters/gov/states/nc/ncdhhs/tanf/income/unearned.yaml (comment-only change).
   • Added comment: # general_assistance is not counted per the WF-114 income chart (page 11); the file's reference href anchors wf-114_1-2-2024.pdf#page=6. Comment says page 11, reference anchors page 6. The WF-114 PDF host returned HTTP 403 (not verifiable remotely). Reconcile the page pointer (ideally add the correct #page= for the GA exclusion). No list value changed, so moderate severity.

5. ME: add a direct financial_assistance-counts test.

   • Files: policyengine_us/parameters/gov/states/me/dhhs/tanf/income/sources/unearned.yaml (NEW) + policyengine_us/tests/.../me_tanf_gross_unearned_income.yaml.
   • The ME list counts financial_assistance and excludes general_assistance, and the PR simultaneously re-scopes financial_assistance's doc ("from friends or relatives"). No test asserts financial_assistance positively counts; Case 2 uses gi_cash_assistance as the "other included source." A direct financial_assistance positive case would nail the list membership the PR is really about (GA out, financial_assistance in — the two are easy to conflate). Edge test on an already-covered variable → Should Address, not Critical.

6. DC / MT / WIC / school meals — add same-file GA-absent controls.

   • DC's new case proves GA is now counted (general_assistance 1,200 → dc_tanf_countable_unearned_income 1,200) but has no GA=0 control in-file; MT's new Case 6 proves counted with no GA-specific zero control; WIC/school-meals GA cases assert GA-present = base + 3,000 with only an implicit control. (IL already has an explicit exempt-source control.) A tighter same-period GA-absent control would make each delta unambiguous. All are already-tested variables → Should Address.

Suggestions

1. ME financial_assistance vs general_assistance distinction is correct — no action. financial_assistance (cash from friends/relatives) is genuinely distinct from general_assistance (government GA). ME keeping the former while excluding the latter is faithful to 10-144 C.M.R. Ch. III §B(2)(d). (The §B(2)(k) partial gift exclusion up to $150/quarter is a pre-existing un-modeled choice, not introduced here.)

2. me_tanf_gross_unearned_income is behavior-preserving — the new ME source list is item-for-item identical to the federal list ME previously consumed (both exclude general_assistance, both include financial_assistance), so ME's numeric output is unchanged. Legitimate self-containment refactor matching the established {st}_tanf_gross_unearned_income pattern. The federal tanf_gross_unearned_income remains intact for ~40 other state programs. Consider noting in the PR description that ME behavior is unchanged (documentation/self-containment refactor, not a value change).

3. CO exclusion subsection unverified — co/.../tanf/income/unearned.yaml comment cites 9 CCR 2503-6 §3.605.4(A)(7) for the GA exemption, but the file's reference points at §3.605.3 (countable-income definition). Source PDF is 403-gated. Comment-only, no list change. Suggest verifying 3.605.4(A)(7) and adding a §3.605.4 reference alongside §3.605.3 if used as authority.

4. New ME variable reference parity — me_tanf_gross_unearned_income.py uses a single bare-URL reference (valid); the sibling me_tanf_countable_unearned_income.py uses a two-element tuple citing both the statute and the CMR. Optional: add the 22 M.R.S.-style statute URL for parity. Not required.

Validation Summary

Check	Result
Regulatory	GA count/exclude treatment correct for all seven programs; one MT scope-proxy note, one school-meals subsection nit
References	Correct except WIC wrong-subsection citation (Critical) + WIC file-level over-broad cite; NC/CO citations 403-gated, unverified
Code patterns	Pass — 0 critical, 0 should; naming, aggregation, period/entity, changelog all clean
Test coverage	New me_tanf_gross_unearned_income directly unit-tested (GA excluded + other source included + earned excluded); each changed program has a positive GA-counted test; ME integration proves end-to-end that GA does not reduce the benefit; control/edge gaps only
CI status	Passing

Branch Status

⚠ PR branch is 24 commits behind main. Consider rebasing before merging. Review was scoped to the PR's actual changes — staleness did not affect findings.

Review Severity: REQUEST_CHANGES

🤖 /review-program

[DTrim99]

Requesting changes on one citation-precision defect: the WIC sources.yaml general-assistance entry cites 7 CFR 246.7(d)(2)(ii)(A) (monetary compensation for services / wages), but public assistance is subsection (E). General Assistance IS correctly countable for WIC — just fix the cited subsection. Full findings (plus 6 should-address and 4 suggestions, mostly reference-precision and same-file negative controls) posted above. 🤖 /review-program

[hua7450]

Addressed the review in 0b558fd and merged main (e21799b).

• Critical, WIC citation: comment now cites 7 CFR 246.7(d)(2)(ii)(E). The file-level reference is a single link to the full (d)(2)(ii) income definition, which covers both (A) for wages and (E) for public assistance, rather than two anchors into the same section.
• School meals: comment and reference now point at 245.6(a)(5)(ii).
• Montana: comment states that general_assistance is a proxy for BIA General Assistance, citing TANF 501-1 and Mont. Admin. r. 37.78.402.
• North Carolina: comment explains the reference anchors the chart start (page 6) and the General Assistance row is on page 11.
• Colorado: verified 3.605.4(A)(7) on page 48 of the PDF; added the Cornell 3.605 page as a second reference.
• Maine: added a positive financial_assistance case; variable reference now cites both 22 M.R.S. § 3762 and the CMR. Maine's output is unchanged, noted in the description.
• Controls: general-assistance-absent cases added for DC, Montana, WIC, and school meals.

No list values or formulas changed.

[DTrim99]

Program Review (re-review) — PR #9384 (general assistance as unearned income)

Counts general_assistance as unearned income in the TANF, WIC, and school-meals income-source lists (and correctly excludes it where the governing rule exempts it). Re-review of PR head e21799b7b5e101f78704b6ee78ae24ac993c5064, scoped to the merge-base diff only (Lifeline/LIHEAP/SNAP-utility content already in main was ignored). Prior round was CHANGES_REQUESTED (1 critical / 6 should / 4 suggestions); the author pushed fixes.

Response to prior review

#	Prior item	Severity	Status
1	WIC GA citation pointed at 246.7(d)(2)(ii)(A) (wages) instead of (E) (public assistance/welfare)	CRITICAL	RESOLVED — now cites 7 CFR 246.7(d)(2)(ii)(E); file-level ref broadened to (d)(2)(ii) (#d_2_ii) for the multi-source list. Verified against CFR.
2	WIC file-level ref too narrow (A-only)	SHOULD	RESOLVED — broadened to (d)(2)(ii).
3	School-meals cite bare (a)(5) instead of (a)(5)(ii)	SHOULD	RESOLVED — now 7 CFR 245.6(a)(5)(ii) (#a_5_ii), the "welfare" income-source list. Verified.
4	CO cited §3.605.3, not §3.605.4(A)(7)	SHOULD	RESOLVED — second ref added: 9 CCR 2503-6 §3.605.4(A)(7) — Exempt Unearned Income (General Assistance). Verified verbatim.
5	ME needed a direct financial_assistance-counts test	SHOULD	RESOLVED — me_tanf_gross_unearned_income.yaml Case 4 (financial_assistance: 2_400 → 200).
6	DC/MT/WIC/school-meals lacked same-file GA-absent negative controls	SHOULD	RESOLVED — each of the four files gained a general_assistance: 0 control asserting only the non-GA income.
7	MT: general_assistance used as BIA General Assistance proxy without documentation	SHOULD	RESOLVED — comment now documents the proxy and leads with TANF 501-1 ("BIA General Assistance; countable").
8	NC comment says GA row is on page 11, but href anchors wf-114_1-2-2024.pdf#page=6	SHOULD	STILL OPEN — unverifiable (WF-114 PDF 403s to automated fetch). See Should Address.

Prior tally: 1 CRITICAL + 6 SHOULD + 4 SUGGESTION → 7 of 8 tracked items RESOLVED, 1 STILL OPEN (NC anchor).

Critical (Must Fix)

None.

Should Address

1. NC WF-114 internal page inconsistency — carried over, unverifiable. policyengine_us/parameters/gov/states/nc/ncdhhs/tanf/income/unearned.yaml: the reference href anchors wf-114_1-2-2024.pdf#page=6, but the new inline comment states the General Assistance row is on page 11, so the link does not land the reader on the row corroborating the GA-is-exempt claim. Could not independently confirm the correct page — the WF-114 PDF returns HTTP 403 to automated fetch, so this needs manual lookup. Fix is either (a) if the GA row truly is on printed page 11, add a second anchor/ref to the GA row's actual file page while keeping #page=6 for the chart start, or (b) correct whichever of the two page numbers is wrong. Do not blindly repoint #page=6→#page=11 without confirming the printed-vs-file page offset. This is a comment/anchor consistency issue only — no data or list change is affected, so it does not block on correctness.

Suggestions

1. MT admin-rule cite vs TANF 501-1. policyengine_us/parameters/gov/states/mt/dhs/tanf/income/sources/unearned.yaml: the GA line co-cites TANF 501-1 and Mont. Admin. r. 37.78.402. 37.78.402 is a generic "all available income counted unless excluded" catch-all and does not name BIA/General Assistance; the BIA-GA specificity rests on TANF 501-1 (which the comment already leads with). Optionally drop or de-emphasize the 37.78.402 cite for the GA line to avoid implying it names BIA GA.
2. CO dual-host references. policyengine_us/parameters/gov/states/co/cdhs/tanf/income/unearned.yaml: the two GA-exemption refs point at the same rule via two different hosts (SOS PDF #page=45 for 3.605.3; Cornell for 3.605.4(A)(7)). Harmless; consider a single canonical host for consistency.
3. ME gross Case 2 isolation. me_tanf_gross_unearned_income.yaml Case 2 combines the GA-excluded assertion with gi_cash_assistance: 1_200 in one case (correct and verifiable: 250-less-GA math), but a pure general_assistance-alone → 0 case would isolate the exclusion even more cleanly. Non-blocking.
4. Negative-control paired assertion. The DC/MT/WIC/school-meals general_assistance: 0 controls prove GA does not spuriously add, but do not assert the GA-positive delta against the GA-zero baseline within a single scenario; the paired positive tests in the same files already cover that gap, so this is cosmetic only.

Validation Summary

• Regulatory: 0 critical / 0 should / 2 suggestions. Every state/program counts-or-excludes GA in agreement with its cited authority: DC (D.C. Code §4-205.05(4)) and IL (89 Ill. Adm. Code 112.100(c)) correctly count; MT correctly counts BIA GA via the general_assistance proxy (TANF 501-1); CO (§3.605.4(A)(7)), NC (WF-114), and ME (10-144 C.M.R. Ch.331 Ch.III §B(2)(d)) correctly exclude; WIC and school meals correctly count. All three prior regulatory items resolved.
• References: 0 critical / 1 should / 1 suggestion. Prior CRITICAL WIC cite and 3 of 4 prior SHOULD/SUGGESTION ref items resolved; every added/changed reference corroborated against source (CFR, state codes, ME rule). Only open item is the NC page-number anchor (unverifiable, 403).
• Code: 0 critical / 0 should / 2 suggestions (both out-of-scope flags for other reviewers, not code issues). ME rewire confirmed: me_tanf_countable_unearned_income now add(..., ["me_tanf_gross_unearned_income"]); new me_tanf_gross_unearned_income (Person/MONTH, adds the ME-specific period: year source list, /12 handled by framework) is a legitimate state override, not a duplicate. Naming, aggregation, period usage, reference format, parameter formatting, changelog fragment (general-assistance-income-sources.fixed.md) all clean. No hardcoded values or TODOs.
• Tests: 0 critical / 0 should / 2 suggestions. Both prior SHOULD items resolved with specific new tests. The one genuinely new formula variable, me_tanf_gross_unearned_income, has direct unit coverage (4 cases: SS in, GA out + gi_cash in, earned excluded, financial_assistance in) plus integration coverage (regression case confirms GA does not reduce the benefit: me_tanf unchanged at 895). Rewired countable path still exercised by its 8-case test. IL gross var also covered (inclusion + exempt-source control).
• CI: Not run in this read-only re-review. Definitional/list-only change with new unit + integration tests; no dollar-table PDF audit applicable (see PDF manifest — definitional PR).

Branch Status

Branch is up to date with main (BEHIND = 0); no stale-branch concern.

Review Severity: APPROVE

No critical findings survived the fixes. All 7 actionable prior items are resolved; the single remaining SHOULD (NC page anchor) is an unverifiable citation-anchor cosmetic that affects no data, list, or calculation and can be addressed in a follow-up. Regulatory, code, and test dimensions are fully clean.

🤖 /review-program

[DTrim99]

Approving — the prior CHANGES_REQUESTED is resolved: the WIC critical (246.7(d)(2)(ii) (A)→(E)) is fixed, and 6 of the should-address items (school-meals (a)(5)(ii) pin-cite, CO §3.605.4(A)(7) ref, MT BIA-proxy note, the direct ME financial_assistance-counts test, and DC/MT/WIC/school-meals same-file GA-absent controls) are all addressed. The one remaining should-address — the NC WF-114 #page=6 anchor vs the "page 11" comment — is an unverifiable citation-anchor cosmetic (the source PDF 403s automated fetch) with no data or calculation impact; fine as a non-blocking follow-up. Branch is now up to date with main. Full findings above. 🤖 /review-program