Florida TCA applies the $90 and $200 and 1/2 earned income disregards once per unit instead of to each earner #10449

Summary

The Florida TCA earned income disregards ($90 standard, then the $200 and 1/2) are applied once to the unit's total earnings. The DCF ESS manual applies both to each individual with earnings. For a unit with one earner the result is the same. For a unit with two or more earners, PolicyEngine counts too much earned income and pays too little TCA.

This was found in the review of #10248, which fixes the eligibility test and the $110 remainder but does not change the unit-level structure.

Law

DCF ESS Program Policy Manual, chapter 2400, PDF page 27 (printed page 22), 2420.0304 Standard Earned Income Disregard (TCA):

The standard earned income disregard must be budgeted for each individual whose earned income is considered in determining eligibility.

The first $90 of each individual's gross earned income is deducted in a regular budget.

Same chapter, PDF page 28 (printed page 23), 2420.0314 $200 and 1/2 Earned Income Disregard (TCA):

Each individual (who has earnings and is otherwise eligible) whose needs are considered in determining eligibility for Temporary Cash Assistance and Family-Related Medicaid (MFAM) may be eligible for a disregard of a portion of the individual's remaining earned income following the standard earned income deduction.

Same page, 2420.0315 Eligibility for $200 and 1/2 Disregard (TCA):

In order for a member of a Temporary Cash Assistance (TCA) standard filing unit (SFU) to receive the $200 and 1/2 disregard, the individual must:

Fla. Stat. 414.095(11)(a) also states eligibility per individual, but it does not say whether the amount is per earner or per unit:

As an incentive to employment, the first $200 plus one-half of the remainder of earned income shall be disregarded. In order to be eligible for earned income to be disregarded, the individual must be: 1. A current participant in the program; or 2. Eligible for participation in the program without the earnings disregard.

One source reads the other way. Chapter 2600, PDF page 21, 2620.0111.01 Income Test and Benefit Determination (TCA), starts from the total:

Step 1 - Total the gross earned income.
Step 2 - Subtract the standard disregard of $90.
Step 3 - Subtract the remainder of $200 and 1/2 earned income disregard, if eligible.

This issue follows 2420.0304 and 2420.0314, which state the rule for each disregard and name each individual. The 2620.0111.01 steps give the order of operations. rulespec-us encodes both disregards on Person in us-fl/policies/dcf/ess-program-policy-manual/2400-budgeting-income/page-28.yaml.

PolicyEngine

policyengine_us/variables/gov/states/fl/dcf/tanf/income/fl_tca_countable_earned_income.py (SPMUnit) sums the unit's earnings and subtracts one $90 and one $200 and 1/2. On main:

gross_earned = add(spm_unit, period, ["tanf_gross_earned_income"])
after_standard = max_(gross_earned - p.standard_disregard, 0)
...
remaining_after_first = max_(after_standard - p.first_amount, 0)
countable_with_full_disregard = remaining_after_first * (1 - p.remaining_rate)

On the #10248 branch the remainder is p.first_amount - p.standard_disregard ($110), but the subtraction is still once per unit. fl_tca_200_and_half_disregard_eligible is also an SPMUnit variable.

Example

January 2024. Two parents and two children (ages 8 and 5), shelter obligation over $50, so the payment standard is $364. The unit is enrolled (is_tanf_enrolled: true), so 2420.0315 condition 1 makes each parent eligible for the $200 and 1/2.

PE gives the same amount for both splits. Under the manual, the two-earner family gets $100 more. (On main both rows are $0 because of #9982, which #10248 fixes.)

Suggested fix

Compute the $90 and the $200 and 1/2 on each person and sum the results, as ak_atap_countable_earned_income_person does for Alaska. Keep the eligibility test of 2420.0315 condition 2 at its current level unless a source settles whether "gross countable income" there is the individual's or the SFU's; this issue does not depend on it, because condition 1 applies in the example.

Related: #10248, #9982.