Wisconsin Works: CMC ignores the other-adult exclusion and ARP ignores the unmarried, no-dependent-child condition (Wis. Stat. 49.148(1m)(a)) #10493

Summary

wi_works_placement gives the Custodial Parent of an Infant (CMC) placement whenever any unit member is at or below the infant age limit, and the At Risk Pregnancy (ARP) placement whenever any member is in month 7 or later of a pregnancy. The statute adds conditions to both placements that the model does not check. Both gaps predate #10259, which fixes only the infant's age; DTrim99 raised them in the #10259 review (Suggestion 4).

The law

Wis. Stat. 49.148(1m)(a):

Any of the following may receive a monthly grant of $673: 1. A custodial parent of a child 8 weeks old or less who meets the eligibility requirements under s. 49.145 (2) and (3), unless another adult member of the custodial parent's Wisconsin Works group is participating in, or is eligible to participate in, a Wisconsin Works employment position or is employed in unsubsidized employment, as defined in s. 49.147 (1). 2. An unmarried woman who would be eligible under s. 49.145 except that she is not a custodial parent of a dependent child and who is in the 3rd trimester of a pregnancy that is medically verified and that is shown by medical documentation to be at risk and to render the woman unable to participate in the workforce.

W-2 Manual 7.4.3.1: "If another adult in the W-2 Group is working in unsubsidized employment or is eligible for W-2 participation, regardless of the W-2 Group's income, the family is not eligible for CMC." The family "would be considered a two-parent family and be treated accordingly" (Chapter 14). Examples 1-3 deny CMC (a working co-parent, a working spouse, a spouse who is W-2 eligible); Example 4 allows it (the spouse receives SSDI and is not W-2 eligible).

What the model does

policyengine_us/variables/gov/states/wi/dcf/works/wi_works_placement.py:

• CMC. has_infant = spm_unit.any(age_in_weeks <= p.cmc_infant_age_limit). It does not check for another adult who works or is W-2 eligible.
• ARP. spm_unit.any(is_pregnant & in_third_trimester). It does not check that the woman is unmarried and is not a custodial parent of a dependent child. It also does not check the medical at-risk condition (this one is likely an input).

Example

Take integration Case 8 (two parents, one earns $1,500 a month, $1,500 in cash assets), and replace the 4-year-old with a newborn:

• Model. CMC, $673.
• Law. The other parent works in unsubsidized employment, so CMC is not available (Manual 7.4.3.1 Examples 1 and 2). The family is a two-parent family, with the CSJ grant of $653 at most.

A married woman in month 7 of a pregnancy, or one who already has a dependent child in the unit, gets ARP ($673) in the model. The statute limits ARP to an unmarried woman who is not a custodial parent of a dependent child.

Possible approach

• CMC: deny when another adult (head or spouse other than the custodial parent) has earned income, or is not exempt from W-2 participation (for example, not receiving SSI or SSDI). The exact test for "eligible to participate in a W-2 employment position" needs a check against Manual Chapter 14 and DCF 101.
• ARP: require that the pregnant person is not married and that the unit has no dependent child of hers. Treat the medical at-risk documentation as an input, or document that the model assumes it.
• Add YAML cases from Manual 7.4.3.1 Examples 1-4.

Axiom

TheAxiomFoundation/rulespec-us#1948 (the 49.148 parity issue for #10259) already lists the other-adult condition among its required outputs and companion tests.