MA CCFA: correct eligibility, service-need and copay rules

## Current scope

Income PR #9460 is merged. Draft PR #9468 addresses the remaining eligibility and copay corrections within the model's existing parent-and-child household scope. It replaces the relevant parts of the reverted #9457; #9458 remains the revert of that original PR.

We compared other state CCDF implementations and are keeping the same practical scope: reuse shared activity, disability, student, TANF-enrollment and child-care attendance inputs. Do not introduce agency-approval or authorization-history inputs just to reproduce every administrative procedure. Nonparent caretaker/grandparent households remain outside scope.

## Covered by draft #9468

These items remain pending until the draft is reviewed and merged:

- [ ] Inclusive $1 million asset boundary and documented homeless/TAFDC asset exemptions.
- [ ] Historical 85% SMI initial-income exception for families with an eligible child with a disability. The general January 2026 entry-limit increase was already encoded.
- [ ] October 2023 homeless income and parent-fee exemptions, retaining the explicit advisory rule subject to the clarification below.
- [ ] Individual parental activity eligibility: remove the blanket pregnancy/disability family exemption; reuse `is_disabled`, `is_full_time_student`, work hours, retirement and `meets_ccdf_activity_test`.
- [ ] Replace calculated TAFDC eligibility with reported TANF enrollment as the existing DTA-related-care approximation; require an eligible child.
- [ ] Rank eligible children attending care, apply sibling discounts and the half-day fee reduction, and cap each child's fee at modeled reimbursement.
- [ ] Add the existing `CONDITIONAL_ENTRANT` enum to the qualifying child immigration list.

PR #9468 adds only two derived variables, `ma_ccfa_copay_person` and `ma_ccfa_is_part_time_care`, and no new factual or agency-approval inputs. Its CCFA suite has 187 passing cases, including date boundaries and multiple-family integration.

## Remaining policy questions and limitations

- [ ] Clarify with EEC whether omission of the explicit homeless no-income-collection sentence in the May 2026 consolidation changes the October 2023 rule, reiterated in April 2024. No rescission was found; #9468 retains the earlier advisory and documents this uncertainty.
- [ ] Review remaining qualifying child immigration categories not represented by the shared enum. Do not impose a parental citizenship requirement.
- [ ] Income mapping: obtain a lottery-specific input contract before treating all `gambling_winnings` as lottery; investigate earlier PFML countability and mappings into other tax/benefit programs, EEC self-employment expense adjustments and historical specialized VA exclusions.
- [ ] Document remaining family-composition, attendance-as-placement and enrollment-as-referral approximations for API consumers.

## Deliberately outside current modeling scope

The following are policy findings, not a commitment to create new input variables:

- School-year age-out extensions through June 30 or the current authorization end, whichever is later. The [December 2025 slides](https://www.mass.gov/doc/december-2025-ccfa-policy-and-procedure-slides/download), pp. 3, 5 and 11–14, establish January 1, 2026 implementation. Continue using current-age eligibility, consistent with the other state models reviewed.
- Authorization dates, parent-fee locks, provisional periods and renewal history. April 2025 introduced limited 12-week provisional periods and ended the blanket provisional fee waiver.
- Detailed Pathway prior-use/expiration, approved parental leave and military-deployment histories. The ordinary employment floor remains 20 hours; the April 2025 15-hour Pathway is conditional. Use the existing shared activity input for qualifying activities not individually modeled; pregnancy or PFML receipt alone is insufficient.
- Detailed college-credit and graduate-study eligibility. April 2024 recognizes 25 hours as full-time and 10 college credits at 2.5 hours each; the current model retains the full-time-student approximation.
- DTA/DCF referral issuance, transitional care windows and fee-free authorization history. TANF enrollment is an approximation, not proof of a referral.
- Occasional-care sibling reordering and provider placement histories.
- Nonparent caretaker/grandparent cases, waitlist priorities, provider enrollment payments, communications and portal procedures. Annual rate and fee-table maintenance is separate from this rule audit.

## Evidence

- [February 2022 guide](https://www.mass.gov/doc/eecs-financial-assistance-policy-guide-february-1-2022/download): asset/income eligibility, service needs, fees and child immigration categories. February 2022 marks verified historical coverage for the exemptions; it is not asserted to be their original adoption date.
- [October 2023 advisory](https://www.mass.gov/doc/eec-policy-advisory-field-operations-2023-4-child-care-financial-assistance/download), pp. 1–3: expressly identifies the changes effective October 1 amid a phased rollout.
- [April 2024 advisory](https://www.mass.gov/doc/eec-policy-advisory-field-operations-7-child-care-financial-assistance-updated-policy-guidance/download), pp. 4–6.
- [April 2025 advisory](https://archives.lib.state.ma.us/server/api/core/bitstreams/5c538ae6-69c2-43df-bf85-10d2f5e5bfc2/content), pp. 2–6.
- [May 2026 manual](https://www.mass.gov/doc/eec-ccfa-2026-04-income-eligible-consolidated-policies-may-6-2026/download), pp. 19–23, 25–35 and 44–46.

Follow-up to #9455. Keep this issue open for the unresolved questions after #9468 merges.

Start by reviewing draft PR #9468 and its 187-case CCFA suite, then read the cited February 2022 through May 2026 policy documents. This issue is complete only after the covered corrections are merged and the remaining policy questions and modeling limitations are resolved or documented.

Written by the indexing model from the issue text.