[MaxGhenis]

The Maryland Public Assistance to Adults (PAA) and California State Supplementary Payment (SSP) formulas now count each month's SSI in-kind support and maintenance (ISM) in that month. The California change applies to a couple in which one spouse receives SSI and the other qualifies for the Cash Assistance Program for Immigrants (CAPI). Both formulas previously spread the year's ISM across twelve equal months. The Maryland formula also reads each month's SSI couple status, as _ssi_couple_income has since #10820.

Changes

• md_paa_countable_income becomes a monthly variable. It applies SSI's $20, $65 and one-half exclusions to each month's income and reads that month's ISM. md_paa and md_paa_imputed_federal_ssi already read it by month.
• md_paa_countable_income reads ssi_couple_computation_applies for the month, the same month _ssi_couple_income reads when it combines a couple's income. A spouse's part-year facility stay now separates the couple's income only in the months it covers.
• ca_state_supplement_person passes the month's income, with the month's ISM, to _apply_ssi_exclusions_monthly when it computes the SSI spouse's own countable income in such a couple. Its other paths already use monthly ssi_countable_income.

Sources

• Maryland pays "the amount by which the allowable needs exceed the net countable income in that month" (COMAR 07.03.07.09(A)), and applies its disregards to earned income "in any month" (COMAR 07.03.07.08(A)). Under the PAA Manual, section 900, caseworkers apply to earnings the part of the $20 disregard that unearned income under $20 leaves unused. They price a Rehabilitative Residence's cost of need at 30 days of its daily rate.
• SSA administers California's supplement and determines eligibility "using federal criteria" (CDSS). It determines a supplement's countable income "in the same manner" as SSI income (20 CFR 416.2025(b)).
• SSA uses "the in-kind support and maintenance you receive in the month" (20 CFR 416.1130(a)). It determines benefits "for each month", generally from income in the second prior month (20 CFR 416.420, POMS SI 02005.001).
• SSA counts an eligible couple's "combined income" (20 CFR 416.1802(b)(1)), and in a month one spouse spends in a medical treatment facility it counts "each individual's own countable income" (20 CFR 416.414(b)(3)).
• SSA stopped counting food as ISM on September 30, 2024 (89 FR 21199), so it counts no food ISM in December 2024 payments, which use October income.
• The California cases use SSA's January 2024 payment levels (POMS SI 01415.056).

Methodology choices

• The Maryland formula counts SSI's ISM, with SSI's payment-month dating, for every PAA recipient. Neither COMAR 07.03.07.07 to .09 nor the PAA Manual has an in-kind support rule, and the formula counted SSI's ISM before this change. For an SSI recipient, imputed federal SSI moves by the opposite amount and PAA stays the same. For a PAA recipient with no SSI, the payment falls by each dollar of ISM above the $20 exclusion.
• The Maryland formula still halves an SSI couple's combined income for each spouse, and now dates the couple status by month.
• The California formula keeps the couple's presumed maximum value for the SSI spouse in a split couple, because SSI still treats the pair as a couple.

Examples

A 70-year-old in a Maryland Level C care home receives food from others all through 2024. ISM equals $334.33 (one-third of the $943 federal rate plus $20) from January to November and $0 in December.

2024	Countable income before	Countable income now
January	$286.47	$314.33
November	$286.47	$314.33
December	$286.47	$0.00
Year	$3,437.67	$3,457.67

Before, the formula took $3,677.67 of annual ISM, divided it by 12 and subtracted $20 each month. December's unused $20 exclusion no longer offsets income in other months, so annual countable income rises by $20. An SSI recipient's PAA payment stays at $328 in January and $332 in November and December, because imputed federal SSI moves by the opposite amount. A PAA recipient with no SSI gets $956.67 in January (before, $984.53) and $1,275.00 in December (before, $988.53).

A 72-year-old citizen in California receives food from others all through 2024, and their 68-year-old spouse qualifies for CAPI.

2024	SSP before	SSP now
January	$280.58	$239.61
November	$280.58	$239.61
December	$44.75	$475.44
Year	$3,131.13	$3,111.15

Through November the citizen's SSI of $471.67 and SSP of $239.61 sum to $711.28: the $1,182.94 individual standard less $471.67 of own countable income, with the supplement rounded up to the cent. In December SSI of $707.50 and SSP of $475.44 sum to $1,182.94.

A 2025 Maryland couple aged 72 and 70 has $1,000 a month of wages and $1,000 of unearned income for the first spouse and $500 of unearned income for the second. The second spouse enters a Medicaid-funded facility in July.

2025	First spouse before	Second spouse before	First spouse now	Second spouse now
June	$1,447.50	$480.00	$973.75	$973.75
July	$1,447.50	$480.00	$1,447.50	$480.00
Year	$17,370.00	$5,760.00	$14,527.50	$8,722.50

Before, the annual formula applied December's status, separate, to the whole year. Now each spouse counts half of the couple's $1,947.50 from January to June and their own income from July. The spouses' annual values now sum to $23,250, the couple's income net of exclusions.

Invariants and tests

• A change to December's ISM moves December alone in Maryland's countable income, imputed SSI and PAA and in California's supplement, and each annual value equals the sum of its months (test_state_readers_keep_a_december_ism_change_in_december).
• Constant ISM returns the earlier annual result (test_constant_ism_keeps_the_annual_exclusion_result).
• With ISM under $20, Maryland's countable income equals COMAR 07.03.07.08(A)'s monthly disregards, with the unused part of $20 reducing that month's earnings, and California's supplement moves only in the changed month (test_state_readers_keep_a_small_ism_exclusion_in_its_month).
• md_paa_countable_income.yaml adds January, November, December and full-year 2024 cases, and its part-year facility case checks June, July and the year. The spouses' annual values sum to the couple's income net of exclusions.
• ca_state_supplement.yaml adds the SSI and CAPI couple in the same three months.

Microsimulation impact

To be measured before merge.

Related work

• #10820 combined an SSI couple's income by each month's couple status through _ssi_couple_income, and #10856 added earnings to the Maryland part-year case.
• #10532 also changes the Maryland income reader and both amended YAML files.
• #10146 changes adjacent SSI deeming, and #10639 changes adjacent resource tests.
• medicaid_optional_senior_or_disabled_countable_income stays annual and still sums the year's ISM.

Axiom parity

axiom: TheAxiomFoundation/rulespec-us#1866 (monthly SSI in-kind support, to extend to Maryland PAA), TheAxiomFoundation/rulespec-us#1939 (California split SSI and CAPI couples, to extend to the month's in-kind support) and TheAxiomFoundation/rulespec-us#2191 (couple income by month, to extend to Maryland PAA), queued

🤖 Generated with Claude Code