[MaxGhenis]

#10598, which this PR builds on, merged into main on November 3, 2026.

What this changes

Before TWC's TX3C case management system launched on January 13, 2025, each of Texas's 28 Local Workforce Development Boards set its own Child Care Services parent share of cost (PSoC) scale (40 TAC §809.19; WD 24-23 for BCY 2024; WD 20-24 for BCY 2025). Today the model applies TWC's statewide TX3C scale to every month, including October 2023 to January 2025.

• New tx_ccs_board_copay applies a Board's scale. It reads the family's income as a share of the SMI in force that month, using the fiscal-year SMI that starts each October 1, and TWC's whole-dollar range limits. Those limits are round(share × annual SMI / 12), which reproduces all 252 SMI-range cells in WD 24-23 Attachment 2 and the BCY 2025 ranges.
• New copay/board/applies.yaml holds a switch for each Board. It is true for the periods where the research found the Board's scale, and false from 2025-01-01 (actual effective date 2025-01-13). Where the research found a Board's BCY 2024 scale but no later one, the switch stays true and the model continues that scale until TX3C, as WD 20-24 let Boards do. Where the research found no Board scale, tx_ccs_copay keeps the statewide scale. Every Board's switch starts false at 0000-01-01: the model copies each parameter's earliest value back to 2015 (backdate_parameters), so a switch that started true would apply a Board's first scale from 2015. Months before October 2023 keep the statewide scale, as before this PR.
• Board scales can also use TWC's FPG income ranges, which WD 20-24 let each Board choose instead of the SMI ranges (and WD 24-23 Attachment 2 printed for BCY 2024). TWC's FPG limits follow no single rounding rule, so the new copay/board/fpg_income_limits.yaml holds the printed limits by family size (2 to 15) and FPG percent for October 2023 and October 2024. Where TWC prints * because a limit would pass 85% of SMI, the cell is .inf, so the range below it runs to the eligibility limit. copay/board/uses_fpg_ranges.yaml marks the Boards on FPG ranges; Greater Dallas is the first.
• New copay/board/reduction/ holds the reductions some Boards give, by region. Panhandle's policy CC 3.1 gives 30% off when a child attends a Texas Rising Star provider and 25% off when every child receives part-time or blended care, and a family that qualifies for both gets the greater one. Alamo gives 10% off at a Texas Rising Star provider in BCY 2024, and its chart rounds the discounted share to the dollar (copay/board/reduction/rounds_to_dollar.yaml). Borderplex ended its discounts on October 1, 2023.
• New copay/board/caps_at_income.yaml marks the Boards that cap the share of cost at the family's monthly income. Alamo's charts print the cap ("The parent share of cost cannot exceed the family's monthly gross income"), and the model applies it after any discount.
• A family with no countable income pays nothing under a Board scale, though Board charts start their lowest range at $0. TWC reads 40 TAC 809.19's bar on a minimum share of cost that way (CCDF State Plan 2022-2024, section 3.2.4).

Board scales

Cloud and local research sessions searched each Board's site, Board packets and minutes, the Wayback Machine and Common Crawl for both periods; the private research repository PolicyEngine/tx-ccs-board-psoc holds their records and sources. "Not found" means no Board chart or policy table for that period turned up, so the model keeps the statewide scale. Amounts are monthly.

WDA	Board	October 2023 to September 2024	October 2024 to January 12, 2025
1	Panhandle	SMI ranges, $30-$310 first child, $15-$100 each additional	SMI ranges, $30-$310 first child, $15-$100 each additional
2	South Plains	not found	not found
3	North Texas	not found	not found
4	North Central Texas	not found	not found
5	Tarrant County	not found	not found
6	Greater Dallas	FPG ranges, $26-$286 first child, $11-$121 each additional	FPG ranges, $26-$286 first child, $11-$121 each additional
7	Northeast Texas	not found	not found
8	East Texas	not found	not found
9	West Central Texas	not found	not found
10	Borderplex	SMI ranges, $19-$152 first child, $10-$76 each additional	SMI ranges, $21-$331 first child, $10-$166 each additional
11	Permian Basin	not found	not found
12	Concho Valley	not found	not found
13	Heart of Texas	not found	not found
14	Capital Area	not found	not found
15	Rural Capital Area	not found	not found
16	Brazos Valley	SMI ranges, $25-$200 first child, $10-$80 each additional	BCY 2024 amounts carried over (no later chart found)
17	Deep East Texas	not found	not found
18	Southeast Texas	not found	not found
19	Golden Crescent	not found	not found
20	Alamo	SMI ranges, $30-$290 first child, $0-$140 each additional	SMI ranges, $30-$290 first child, $0-$140 each additional
21	South Texas	SMI ranges, $50-$400 first child, $20-$100 each additional	BCY 2024 amounts carried over (no later chart found)
22	Coastal Bend	not found	not found
23	Lower Rio Grande Valley	not found	not found
24	Cameron County	not found	not found
25	Texoma	not found	not found
26	Central Texas	not found	not found
27	Middle Rio Grande	not found	not found
28	Gulf Coast	not found	not found

Plan

• Design, Panhandle, tests
• FPG income ranges, income caps
• Research the other Boards' charts for BCY 2024 and October 2024 to January 12, 2025. Each Board now has a sourced scale or a documented gap: 6 sourced and 22 gaps. The research found no BCY 2025 chart for Brazos Valley or South Texas, so the model continues each one's BCY 2024 amounts until TX3C.
• Tests from each chart
• Axiom parity issue (Encode the parent share of cost scales Texas Workforce Boards set before TX3C, October 2023 to January 12, 2025 (PE-US PR 10623) TheAxiomFoundation/rulespec-us#2018)
• Independent review: it asked for four changes, made in 34f99b6 (see Review below), and a re-review of the fixes approved.

Review

An independent review at 21ae4d9 checked every chart amount and range limit against the charts, every SMI and FPG cell, the formula, four gap Boards' searches, the tests and the source-conflict entries. It asked for four changes:

• Alamo's rounding. Alamo's chart rounds the discounted share to the dollar, and the model didn't, so it was off by $0.50 in 13 cells. It now rounds.
• South Texas, October 2024 to TX3C. The model gave these months the statewide scale, which no Board applied before TX3C. It now continues the Board's BCY 2024 amounts, as for Brazos Valley.
• Reduction references. 40 TAC 809.19(b) took effect December 1, 2023, not October 1, 2023. The references now say so, and cite (a)(8) and (a)(9) for the months before and the 2024 rule's (g) for part-time care.
• Brazos Valley's part-time reduction. Known limits now discloses it.

It also led to smaller fixes: the Texas Register page in candidates.yaml (47 TexReg 6437), the State Plan's September 1, 2024 date for the 7% cap and WD 06-24 Change 2's undated end of Texas Rising Star discounts in two readings, a zero-income test that now asserts eligibility, and stale wording in the changelog and a test comment.

A re-review at 34f99b6 confirmed each fix and approved. e9d1923 then applied its optional notes: Case 23 puts every child at a Texas Rising Star provider, new Case 25 tests a share that ends in 50 cents, the carried-over chart tests quote the BCY 2024 chart's printed dates, and the changelog no longer says a Board continued its chart. The reviewer approved that delta too.

Modeling decisions

The US hub's rulings log records each reading below under the id shown. The four that choose between 40 TAC §809.19 and TWC's practice (Board scales until TX3C, the 7% cap, the Texas Rising Star reduction and zero income) also have entries in source_conflicts/candidates.yaml: #10598 adds the first, and this PR records its ruling and adds the other three. Their # Source conflict markers follow once the shared register has them.

• Board scales until TX3C (us-tx:ccs-board-psoc-before-tx3c). From December 1, 2023, 809.19 has the Commission establish the PSoC, but the Commission's statewide methodology (adopted November 7, 2022) took effect only with TX3C (WD 06-24, Change 2, p. 2). Until then TWC had Boards set their own amounts (WD 24-23, WD 20-24; FFY 2025-2027 State Plan 3.1.2).
• 7% cap (us-tx:ccs-psoc-7pct-cap-timing). 809.19(a)(1)(C) caps the PSoC at 7% of income from July 29, 2024, but TWC applied the cap only with its statewide scale at TX3C (WD 20-24; FFY 2025-2027 State Plan 3.1.1, which says TWC could not implement it in the old case management system and would seek a federal waiver). Board scales carry no 7% cap. If PolicyEngine settles that a state rule binds like a Treasury regulation, and (C) reaches Board scales by its text, the cap would start July 29, 2024 instead.
• Texas Rising Star reduction (us-tx:ccs-psoc-trs-reduction-end). The July 2024 amendments removed this option. WD 06-24, Change 2 had Boards discontinue the discounts with the statewide policy while families kept current ones through their eligibility period. The model ends the reduction with the Board scales at TX3C, or earlier where a Board ended it.
• Zero income (us-tx:ccs-board-psoc-zero-income). See above.
• Phase-in. TWC phased the statewide scale in as families enrolled or recertified through February 1, 2026, and a family could ask for the statewide amount sooner if it was lower (WD 06-24 Ch. 2 Att. 3; the December 17, 2024 CCDF waiver request). The model has no enrollment date, so it applies the statewide scale to every family from TX3C's launch.
• Exemptions. The model does not cover the Board exemptions (Choices, SNAP E&T, homelessness, protective services), as it does not for the statewide scale.
• Part-time reduction. Panhandle grants "a 25% reduction for each part-time/blended/part-week referral" when every child receives part-time care. The model reads this as 25% off the family's share, not 25% for each child. Read the other way, four children would pay nothing. The rulings log records the reading as us-tx:panhandle-psoc-part-time-reduction.
• Greater of two reductions. 809.19 as amended in 2022 ((a)(9)(B), (b)(8)(B)) gives a family that qualifies for both the Texas Rising Star and the part-time reduction the greater of the two.
• TWC's October 2024 FPG table for large families (us-tx:ccs-fpg-ranges-oct-2024-large-families). The table follows HHS's 2024 guidelines through family size 8, then adds Hawaii's $6,190 per person instead of the contiguous states' $5,380: with that increment every printed limit for sizes 9 to 15 lies within $0.50 of its share. WD 20-24 required Boards to use TWC's ranges and TWC never replaced the file (the March and August 2025 Wayback captures and the live file match), so the model keeps the printed limits.
• FPG family sizes outside TWC's table (us-tx:ccs-fpg-ranges-family-size-outside-table). TWC prints FPG limits for family sizes 2 to 15; the model reads the nearest printed size for other sizes.
• Panhandle's chart misprints (us-tx:panhandle-psoc-bcy24-chart-misprints). Panhandle's BCY 2024 chart prints 4 of its 252 income limits differently from TWC's ranges (family size 5: $2,653 and $2,654 for $3,653 and $3,654; size 6: $7,252 for $7,275; size 13: $6,313 for $3,613). Board policy CC 3.1, effective December 6, 2023, has staff abide by TWC's income ranges (page 100 of the Panhandle Workforce Development Consortium's Governing Body packet for December 7, 2023), so the model uses TWC's limits.
• When Panhandle's reductions start. Policy CC 3.1 took effect December 6, 2023 and prints new text in bold. Its reduction text isn't bold, so it predates that update, and the model applies the reductions from October 1, 2023.
• Brazos Valley's BCY 2025 scale (us-tx:brazos-valley-psoc-bcy25-carryover). The Board published no BCY 2025 chart. WD 20-24 let a Board continue its BCY 2024 amounts without Board action, the Board's minutes from June 2024 to January 2025 hold no PSoC item, and its child care page still showed the FY24 chart on December 11, 2024. The model continues the FY24 amounts on TWC's BCY 2025 ranges until TX3C.
• South Texas's BCY 2025 scale (us-tx:south-texas-psoc-bcy25-carryover). The research found no South Texas chart or Board action for BCY 2025; the Wayback Machine holds no capture of the Board's parents page after March 5, 2024, and its record of the Board's uploads from June 2024 to January 2025 holds no PSoC file. The statewide scale took effect only with TX3C, so the model applies WD 20-24's default, as for Brazos Valley: the BCY 2024 amounts on TWC's BCY 2025 ranges until TX3C. Unlike Brazos Valley's, no Board record confirms this.
• Greater Dallas's 2016 table (us-tx:dallas-psoc-s0408-continuity). The Board's only fee table, in policy S0408, change 5, dates from October 2016. The Board voted in 2019 to keep it, its policy page listed it as current through March 2025, and it adopted TWC's BCY 2024 and BCY 2025 ranges each October. Its August 2023 vote to rescind the local scale awaited TWC's notice, which came with TX3C. The model applies the 2016 amounts on TWC's FPG ranges until TX3C.
• Borderplex's dates (us-tx:borderplex-psoc-dates). The chart and the Board's vote date the BCY 2024 amounts October 1, 2023, though a later CEO slide says November 1; the model follows the chart. The Board rescinded its local scale with TX3C's launch, then due December 9, 2024; TX3C slipped to January 13, 2025, and the Board's page linked its October 2024 chart through January 21, 2025, so the model keeps that chart until TX3C.
• Alamo's Texas Rising Star discount (us-tx:alamo-psoc-trs-discount). Policy CCS 12, Change 2 gives "a 10% discount on their assigned PSOC". The model takes 10% off the family's total and rounds to the nearest dollar, halves up, which reproduces all 63 cells of Alamo's BCY 2024 chart by family size. Alamo's chart by child rounds each child's amount instead, which comes to up to $3 more for a family with three or more children; the model follows the chart by family size, as the policy discounts the family's assigned share. The discount ends with BCY 2024: the Board approved removing it in July 2024, and its October 2024 charts print no discount.
• Children counted. Board charts charge by children in care. Like the statewide branch of tx_ccs_copay, the model counts each eligible child as in care.
• Part-time reductions after TX3C. Boards could keep part-time reductions under the statewide scale (WD 06-24, Change 2). This PR does not model that; it is a follow-up.

Invariants

copay/test_tx_ccs_board_income_ranges.py states these for board_scale_amount, with Hypothesis generating the charts, incomes and SMIs:

• The amount is always one of the chart's amounts.
• A family at a range's limit pays no more than that range's amount, and a family a dollar above pays at least the next range's amount.
• The amount never falls as income rises, and never rises as SMI rises.

For TWC's FPG table (fpg_income_limits.yaml):

• Each printed limit lies within $1 of its share of the annual guideline over 12, read from PE's gov.hhs.fpg, with the October 2024 large-family increment stated as an intended exception.
• A cell is .inf exactly where the limit would pass TWC's 85% SMI limit, read from PE's SMI.
• Every family of size 2 to 15 lands in the right range at each printed limit and a dollar above it, and above the last printed limit stays in the range that runs to 85% of SMI. Sizes 1, 16 and 17 read the nearest printed size; that check confirms the model's choice, not TWC's limits.
• Every FPG Board threshold names one of TWC's ranges (Greater Dallas's do).

For the switch: no Board's scale applies before October 1, 2023, and every Board whose switch turns on has a scale for each date it does. The test reads the loaded (backdated) parameters at January 1, 2015 and September 30, 2023, and checks that each Board's switch starts false.

Starting Panhandle's switch true, as before the fix, fails three tests, and a switch that reads Panhandle's flag for every region fails Case 16. Dropping the income cap fails Case 17, and applying it before the discount fails Case 21. Switching Brazos Valley's BCY 2025 scale off fails its four BCY 2025 chart cases, and turning Greater Dallas's FPG flag off fails all eight of its cases. Five FPG mutants each fail a test: ignoring the FPG flag, a reform with the flag off, ignoring the percent in the lookup, making a * finite, and moving one limit by $3. Two earlier formula mutants confirm the SMI tests bite: charging the upper range at the limit (>= for >) fails the limit test, and reversing the comparison fails three of the four. The same file checks that every Board scale rises with income and every reduction stays between 0 and 1.

Known limits (not changed here)

• SMI timing outside the Board path. tx_ccs_income_eligible and the statewide branch of tx_ccs_copay read hhs_smi, a yearly variable, so October to December use the previous fiscal year's SMI. The Board path reads the SMI in force that month. So in October to December 2024, a family between 85% of the FY 2024 and FY 2025 SMI counts as ineligible, though TWC's BCY 2025 limits cover it. This predates this PR and is a follow-up.
• Brazos Valley's part-time reduction. Texas's FFY 2025-2027 State Plan (3.2.1, p. 51) lists Brazos Valley among the 12 Boards that reduce the share of cost for part-time or blended care, and its FY24 chart says no discount applies to after-school (blended) care. The research didn't find the reduction's size, so the model applies none and overstates the share for a Brazos Valley family whose children are all in part-time care.
• Counties outside every Board list. tx_ccs_workforce_board_region maps the household's county to its Board and falls back to Panhandle when the county matches no Board's list, so such a household gets Panhandle's scale from October 2023 to TX3C. A Texas household with no county set reads Anderson County, in East Texas, and keeps the statewide scale.
• Texas School Ready providers. The Texas Rising Star reduction counts providers rated TRS2 to TRS4. Whether a provider rated TSR also qualifies is open; the open ruling us-tx:ccs-tsr-school-age-enhanced-rate asks a related question.

Known interactions

• PR Count state child care subsidies in the SPM once #10569 adds a 2024 Texas case to spm_child_care_subsidies_integration.yaml ("Texas, a program the 2024 list left out") with no county set. That household reads Anderson County, in East Texas, where the research found no Board chart, so it keeps the statewide scale and its expected value doesn't change with this PR.

Tests

• copay/tx_ccs_board_copay.yaml covers Panhandle's range limits on both sides of each boundary tested, including TWC's rounding at the 20% SMI limit, zero income, the September to October 2024 SMI switch, the reductions, a November 2024 share above 7% of income, and the Texas Rising Star reduction in November 2024. It covers Alamo's income cap (alone and after its discount), Alamo's discount, its rounding and its end (Case 22: 90% of $75 is $67.50, and the chart prints $68; Case 23 has three children; Case 25 rounds $328.50 up, in the more than 70% to 75% SMI range), Brazos Valley's merged top range, and Brazos Valley's part-time care, which gets no reduction (Case 24). The zero-income case asserts that the family is eligible. It also covers the statewide scale where no Board scale applies: Panhandle in September 2023 (Case 15), Panhandle in January 2025 (Case 8), and North Texas, where the research found no chart, in March 2024 (Case 16), a month when Panhandle's own scale applies.
• copay/board/<board>.yaml (generated from each chart) tests each sourced period at a range limit and the dollar above it: the 40% SMI or 100% FPG limit for every Board, plus Brazos Valley's 75% SMI and Greater Dallas's 200% FPG limits, where their top ranges start.
• copay/test_tx_ccs_board_income_ranges.py checks the range limits against all 252 SMI cells of TWC's BCY 2024 and BCY 2025 tables, on both sides of each limit, and the FPG table as above, with an end-to-end case: a reform moves Panhandle's November 2024 scale onto FPG ranges, and a family of three at each printed limit and a dollar above pays the expected amount.
• tx_ccs.yaml Cases 7–8 change from the statewide scale to Panhandle's: the $2,000-a-month case pays $110 instead of $88.45. Case 6 (zero income) still pays nothing.
• Locally, at e9d1923, every YAML file under tx/twc/ccs passes in its own process (198 cases, including 25 in tx_ccs_board_copay.yaml and 32 chart cases), as do the two Texas files under partners/analytics_coverage (11 cases), the 29 tests in test_tx_ccs_board_income_ranges.py, the 33 rate-table tests and every code-health test (529 passed, 1 skipped), test_source_conflicts.py included.

axiom: TheAxiomFoundation/rulespec-us#2018 queued

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[MaxGhenis]

Hand-off to the US + core hub.

• Head: e9d1923, on main after Add Texas CCS Board Contract Year 2024 provider payment rates #10598's squash-merge (56e0a3a).
• Review: an independent Opus 5.5 review at 21ae4d9 checked every chart amount and range limit, every SMI and FPG cell, the formula, four gap Boards' searches, the tests and the source-conflict entries. It asked for four changes, and 34f99b6 makes all four:
  • Round Alamo's discounted share to the dollar.
  • Continue South Texas's BCY 2024 scale from October 2024 to TX3C.
  • Correct the reduction references' dates.
  • Disclose Brazos Valley's part-time reduction.
• Re-review: a re-review at 34f99b6 approved. A check of the delta to e9d1923, which applies the re-review's optional notes, approved too. The record is reviews/pr10623/REVIEW.md in the private research repository PolicyEngine/tx-ccs-board-psoc.
• Local tests at e9d1923, all passing:
  • every YAML file under tx/twc/ccs, each in its own process (198 cases);
  • the two Texas partner files (11 cases);
  • test_tx_ccs_board_income_ranges.py (29);
  • both rate-table tests (33);
  • all of tests/code_health (529 passed, 1 skipped).
• Pending: CI. The PR was a draft until now, so this is CI's first run on it.
• Rulings: the US hub's rulings log holds every interpretive call, under the ids the PR body gives. The review added us-tx:south-texas-psoc-bcy25-carryover and revised us-tx:alamo-psoc-trs-discount (now rounded, following the chart by family size).
• Depends on: nothing open. Count state child care subsidies in the SPM once #10569 (open) adds a Texas case, and this PR doesn't change its value.
• Follow-ups owed (not this PR), listed in the PR body:
  • SMI timing outside the Board path;
  • Board part-time reductions after TX3C;
  • Texas School Ready providers;
  • the # Source conflict markers and the register pin, once the shared register has the four Texas entries.

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[MaxGhenis]

US + core hub merge audit, us#10623 at ea39917c0fa05286a8e34b31e586472a6444f6a8 (squash): Apply Texas Workforce Board parent share of cost scales before TX3C.

• Review: at 21ae4d9d65, an independent Opus 5.5 agent checked every chart amount and range limit, every SMI and FPG cell, the formulas and the tests. It also checked four gap Boards' searches and the source-conflict entries, and asked for four changes. We made them in 34f99b6ecf, and the agent approved that head and the test and comment edits in e9d192338a (hand-off). The hub merged main 54fc324ba2, where Add Texas CCS provider payment rates for October 2016 to September 2023 #10622 landed, into e9d192338a with GitHub's branch update, giving ea39917c0f, and that head's diff from main matches the reviewed diff.

• Source conflicts: we record four readings of 40 TAC §809.19 in source_conflicts/candidates.yaml.

  • us-tx:ccs-board-psoc-before-tx3c: we apply each Board's own scale where we found its chart, and TWC's statewide scale for the other Boards and for every family from TX3C's launch on January 13, 2025.
  • us-tx:ccs-psoc-7pct-cap-timing: we apply the 7% cap only with the statewide scale, from TX3C, as TWC did.
  • us-tx:ccs-psoc-trs-reduction-end: we end each Board's Texas Rising Star reduction with its scale at TX3C, or earlier where the Board ended it.
  • us-tx:ccs-board-psoc-zero-income: a family with no countable income pays nothing under a Board scale.

  In the first three, we follow TWC's practice where the rule's text reads otherwise. If we settle that a Texas agency's rules bind as federal regulations do, we may change them, for months before TX3C only.

• Gates the hub checked live at merge:

  • gh pr checks exits 0;
  • the latest Pull request run at the head concluded success;
  • MERGEABLE;
  • not a draft;
  • no reviewer's latest review requests changes;
  • the semantic-overlap guard;
  • head pinned.

• Impact: no output moves from January 2025 on, 2026 and 2030 included. From that month, every Board's switch in copay/board/applies.yaml reads false, so tx_ccs_copay returns the statewide copay. We change only comments and references in the statewide scale's files. From October 2023 to December 2024, families in the six Boards' regions pay their Board's amounts. In Panhandle, a family of two with one child in care and $2,000 a month pays $110 a month in September and October 2024, against $88.45 under the statewide scale.

• Axiom: we queued the Board scales for encoding in TheAxiomFoundation/rulespec-us#2018.

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