MA CCFA: correct phased income exclusions and related eligibility rules

## Implementation status

The implementation in #9457 was reverted by #9458. Draft #9460 now proposes the income-only corrections. Asset, service-need, and copay corrections are not included in #9460 and remain follow-up work in #9456. The dated policy research below remains applicable.

## Problem

MA CCFA still uses the February 2022 income-source list after phased policy changes. Shared Social Security, SSI and child-support inputs consequently inflate CCFA income and can deny otherwise income-eligible families. Historical dependent-earnings exclusions and support-paid deductions were also missing. This audit excludes routine annual reimbursement-rate and fee-table updates.

## Effective dates established from EEC sources

| Date | Change |
| --- | --- |
| February 1, 2022 documented baseline | Dependent earnings excluded; support/alimony paid deductible; farm/partnership and recurring estate income included; assets **at or below** $1m; homeless asset waiver; initial 85% SMI exception for a disabled child; caregiver fee exemption and half fees for part-time care. These are historical encoding omissions, not new 2026 rules. |
| October 1, 2023 | Exclude Social Security, SSI, child support and dependent/nonparent income. Homeless families receive income-verification and parent-fee exemptions. |
| April 30, 2024 operational rollout | Exclude **veterans disability** benefits. This appeared in the 2023 policy, but April 2024 operational guidance and May training identify the implemented change. |
| April 1, 2025 | Implement parental leave, Pathway to Full-Time Employment, domestic violence, substance use treatment and military deployment service needs. PFML receipts appear in parental-leave guidance by this date; the original PFML countability date is not conclusively established. |
| January 1, 2026 | General initial income ceiling rises to 85% SMI (already encoded). Exclude earnings of any minor, including a minor parent. |
| May 6, 2026 | Consolidation of prior changes, not a common new effective date for all income exclusions. |

Sources:

- [February 2022 guide](https://www.mass.gov/doc/eecs-financial-assistance-policy-guide-february-1-2022/download), PDF pp. 36–40, 76; [self-employment procedures](https://www.mass.gov/doc/financial-assistance-procedures-manual-for-subsidy-administrators/download#page=114).
- [October 2023 operational advisory](https://www.mass.gov/doc/eec-policy-advisory-field-operations-2023-4-child-care-financial-assistance/download), pp. 1–3; [CCDF amendment with explicit October 1 effective date](https://www.mass.gov/doc/ma-eec-ccdf-state-plan-fy-2022-2024-amend-4/download#page=61).
- [April 30, 2024 advisory](https://www.mass.gov/doc/eec-policy-advisory-field-operations-7-child-care-financial-assistance-updated-policy-guidance/download#page=3); [May 2024 refresher, disability marked NEW](https://www.mass.gov/doc/may-2024-ccfa-policy-refresher-slide-deck-0/download#page=19).
- [April 2025 advisory, official State Library archive](https://archives.lib.state.ma.us/server/api/core/bitstreams/5c538ae6-69c2-43df-bf85-10d2f5e5bfc2/content), pp. 1, 5–6.
- [December 2025 training for January 2026 changes](https://www.mass.gov/doc/december-2025-ccfa-policy-and-procedure-slides/download), pp. 5–7.
- [May 2026 consolidated manual](https://www.mass.gov/doc/eec-ccfa-2026-04-income-eligible-consolidated-policies-may-6-2026/download), pp. 21–23, 28–35, 44–46.

## Implementation scope

- [ ] Date income exclusions and support-paid deductions correctly, including historical dependent income and the January 2026 any-minor rule.
- [ ] Add actual PFML receipt input; payroll contribution wages cannot substitute.
- [ ] Distinguish veterans disability from the broader veterans-benefits total and preserve other programs' shared inputs.
- [ ] Include actual farming operations/rent, partnership and recurring estate income without using Schedule J income averaging as farming receipts.
- [ ] Correct the inclusive asset boundary, homeless exemptions and disabled-child initial income exception.
- [ ] Accept active approved April 2025 service statuses; enforce the one-parent parental-leave limit and military second-parent waiver. Do not replace the general 20-hour work floor with the 15-hour Pathway rule.
- [ ] Correct individual rather than family-wide disability treatment; pregnancy alone is not an approved parental-leave authorization.
- [ ] Support caregiver fee exemption and part-time fees after sibling discounts.
- [ ] Add dated regression and final-benefit tests, plus documentation of input contracts and remaining coverage.

Lottery is not mapped to generic `gambling_winnings`: the manuals name lottery specifically and do not establish that all casino/sports gambling is included. A new lottery field is deferred pending integration requirements. Follow-up #9456 tracks authorization history, referral, education and other administrative coverage found in the audit.

Implemented in #9457; awaiting CI/review and merge.

Review #9457, draft #9460, follow-up #9456, and the dated EEC sources to understand which policy corrections remain in scope. Done means implementing the listed dated income, asset, service-need, disability, fee, and input-contract changes, adding dated regression and final-benefit tests, documenting remaining coverage, and passing CI.

Written by the indexing model from the issue text.