Massachusetts TAFDC: dependent care hours band per earner, 100% disregard per member, grant rounding and the $10 minimum #10489

DTrim99's review of #10257 (2026-10-26, suggestion 3) found four gaps in the Massachusetts TAFDC grant path that are outside that PR. I checked each one against main on 2026-10-27. An additional payer-specific financial-eligibility follow-up from the #10257 review is recorded in section 5.

1. Dependent care hours band

106 CMR 704.275(A) ties the maximum to the employed person: "For an applicant or client who is employed full-time ... An applicant or client who is employed less than full-time may receive a proportionate share of the maximum allowable deduction." The hours table starts at "1 - 10" weekly hours.

• ma_tafdc_dependent_care_deduction_person sets the band from the SPM unit's summed weekly_hours_worked_before_lsr. Two part-time earners (for example 20 hours each) get the full-time maximum.
• gov.states.ma.dta.tcap.deductions.dependent_care_expenses.amount.younger and .older start their first bracket at 0 hours, so a unit with no reported hours gets $50 / $44 instead of $0.

2. 100% earned income disregard per member

106 CMR 704.500(A) Step 2: "Subtract 100% of the remaining gross earnings of each member of the assistance unit who is eligible for the 100% Earned Income Disregard." ma_tafdc_full_earned_income_disregard_eligible is a Person variable, but it tests the SPM unit's ma_tafdc_applicable_income_for_financial_eligibility against 200% of the unit's FPG, so every member gets the same result. If this becomes per member, #10257's allocation of the dependent care deduction should be computed only over members outside the 100% window, since their earnings are zero at Step 3.

3. Grant rounding and the $10 minimum

106 CMR 704.500(A) Step 7: "Round this amount down to the next whole dollar. The result, if $10 or greater, but less than the applicable Payment Standard ... is the amount to be paid monthly. ... If the result is zero or greater but less than $10, the assistance unit is considered to be receiving assistance, but will not receive a monthly grant." ma_tafdc_potential_main_benefit is min_(max_(0, payment_standard - countable_income), payment_standard), with no rounding and no $10 minimum.

4. Parameter descriptions

dependent_care_expenses/amount/younger.yaml and older.yaml say the amount is deducted "from the unearned income". 704.275(A) and 704.500(A) Step 3 deduct it from earned income.

5. Payer-specific dependent-care deduction in financial eligibility

The payer-specific benefit calculation in #10257 does not update the financial-eligibility path. ma_tafdc_earned_income_after_deductions still subtracts the unit's dependent-care deduction from the unit's earnings, without using ma_tafdc_dependent_care_payer. An unused deduction attributable to a lower-earning payer can therefore still reduce another member's income in that test.

106 CMR 704.260(A)(1)(c) cross-references the disregarded income provided in 704.275. Section 704.275 assigns the care deduction to the employed applicant or client incurring the expense. The financial-eligibility calculation should honor that payer attribution at the applicable deduction step, floor each payer's remaining countable earned income, and then aggregate; it should not transfer the unused care deduction to another earner.

Follow-up scope:

• Apply the payer-specific care treatment to the financial-eligibility calculation, in addition to the benefit calculation fixed by Subtract the Massachusetts TAFDC dependent care deduction once per unit #10257.
• Coordinate the deduction order and applicant/client income-test distinction with MA TAFDC: work-expense deduction credited to every member; eligibility test omits the 50% disregard #9469. Do not assume Count the MA TAFDC work-related expense deduction once per earner #9477 covers this: its eligibility-side change was withdrawn, and its remaining scope is the per-earner work-expense fix.
• Add a policy YAML regression with a lower-earning payer whose allowable care exceeds their remaining earnings, checking the financial-eligibility result and preventing use of the remainder against another earner.
• Keep the payer-hours correction in section 1 coordinated with this change.

This is a preexisting follow-up outside #10257's scoped benefit-calculation correction.

References

• 106 CMR 704.275

• 106 CMR 704.281

• 106 CMR 704.500

• Official DTA 106 CMR 704, sections 704.260 and 704.275 #page 41,43

The rulespec-us modules us-ma/regulations/106-cmr/704/275/block-1.yaml and 704/500/block-1.yaml already use the member's own hours, give $0 at zero hours, and apply the rounding and the $10 minimum.

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