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Count income of aged, blind, or disabled people who fail SSI's noncitizen test - #10240

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medicaid-abd-noncitizen-countable-income
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medicaid-abd-noncitizen-countable-income

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@hua7450 hua7450 commented Oct 15, 2026 •

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Summary

medicaid_optional_senior_or_disabled_countable_income and ssi_countable_income returned $0 for anyone who was not is_ssi_eligible_individual or is_ssi_eligible_spouse. is_ssi_eligible_individual includes SSI's citizen and qualified-noncitizen test, including the 40-quarter rule for lawful permanent residents. An aged, blind, or disabled person who failed only that test therefore had all income ignored by every program that reuses SSI methodology.

Examples on main (2025):

Household main This PR
MA, age 70, LPR, 10 years since entry, 20 SSI quarters, $60,000 pension countable income $0, is_medicaid_eligible true $59,760, ineligible (same as with 40 quarters)
DC, age 70, undocumented, $60,000 pension countable income $0, eligible $59,760, ineligible
CA, age 68, TPS, $24,000 pension (SF CAAP Case 15) CAPI paid regardless of income CAPI $0

Fix

The zero was meant for the deeming role: a spouse who is not aged, blind, or disabled has their income deemed to the other spouse (20 CFR 416.1163), so their own countable income must be zero to avoid counting it twice. This PR gates that zero on is_ssi_aged_blind_disabled instead of SSI eligibility status:

  • medicaid_optional_senior_or_disabled_countable_income: Medicaid's ABD financial methodology follows SSI's (42 CFR 435.601) and counts the applicant's own income whether or not they meet SSI's noncitizen rules.
  • ssi_countable_income: the medically needy path (is_medically_needy_for_medicaid) reads this variable, so it had the same bypass.
  • defined_for on is_ssi_spousal_deeming_applies, ssi_income_deemed_from_ineligible_spouse and medicaid_optional_senior_or_disabled_income_deemed_from_ineligible_spouse moves from is_ssi_eligible_individual to is_ssi_aged_blind_disabled. Without this, a noncitizen married to a working spouse who is not aged, blind, or disabled would have the spouse's income ignored.

For citizens and qualified noncitizens nothing changes: the old and new gates differ only for aged, blind, or disabled people who fail SSI's noncitizen test. The spouse in an eligible couple already passed the old gate, and deemed income is zero for both members of an eligible couple.

Downstream effects

  • SSI: unchanged. uncapped_ssi is defined_for = "is_ssi_eligible", which still applies the noncitizen test.
  • Medicaid: optional ABD, medically needy, 209(b) spenddown and the MS Healthier Mississippi Waiver now count the income of these noncitizens.
  • CA CAPI: CAPI serves exactly this population, so on main its income test never reduces the benefit. With this PR it counts income; Pay California CAPI from the SSI/SSP standard per person, with spouse-to-spouse deeming #10379 makes CAPI's standard, couple split and deeming match the CAPI regulations (see merge order below).
  • CA state supplement: unchanged for every household. A CAPI-eligible member's income is left out of the supplement's SPM-unit income sum, because CAPI budgets that income (MPP 49-035) and SSI/SSP counts another member's income only when it is deemed (20 CFR 416.1160(a)).
  • Maryland PAA: for people who fail SSI's citizen or qualified-noncitizen test, PAA imputes no federal SSI and counts only their own income (COMAR 07.03.07.07, 07.03.07.09A). Unchanged for citizens and qualified noncitizens.
  • Other SSI-methodology readers for noncitizens who fail the SSI test: MSP spousal deeming, CA WDP, CO OAP and SC SSP now see the person's income.

Review fixes (2026-10-21)

A local review on 2026-10-19 found six critical downstream defects that the old $0 had masked. Disposition:

Finding Disposition
CA state supplement subtracts a CAPI-eligible relative's income from an SSI recipient's supplement Fixed here (ca_state_supplement.py)
Maryland PAA deems spouse income and imputes SSI to people SSI bars Fixed here (md_paa_countable_income.py, md_paa_imputed_federal_ssi.py)
Medically needy test sums income over the tax unit Fixed in #10370 (individual or couple)
CAPI standard leaves out the state supplement portion #10379
CAPI applies the couple rate under deeming without the 416.1163(e)(2) cap #10379 (POMS SI 01320.430)
CAPI pools income across unmarried members of the SPM unit #10379 (per-person CAPI)

Merge order and overlaps

Tests

Regression cases in the variable-named files:

  • medicaid_optional_senior_or_disabled_countable_income.yaml: single LPR with 20 quarters; mixed couple with deemed spouse wages
  • medicaid_optional_senior_or_disabled_income_deemed_from_ineligible_spouse.yaml: mixed couple
  • ssi_countable_income.yaml: single LPR (SSI stays $0); mixed couple
  • ssi_income_deemed_from_ineligible_spouse.yaml: deeming applies to the noncitizen spouse
  • is_medically_needy_for_medicaid.yaml: an over-limit case and a case that qualifies after spenddown
  • is_medicaid_eligible.yaml: the MA and DC examples above, plus a low-income LPR who stays eligible
  • ca_capi.yaml: an aged LPR without 40 quarters whose $24,000 pension leaves no CAPI (holds before and after Pay California CAPI from the SSI/SSP standard per person, with spouse-to-spouse deeming #10379)
  • ca_state_supplement.yaml Case 10: an aged citizen SSI recipient sharing an SPM unit with a CAPI-eligible sibling keeps the citizen-alone supplement ($368.81 a month in 2025)
  • md_paa.yaml Case 11: an aged LPR without 40 quarters in CARE Home Level D with a working spouse gets $998 a month ($1,478 need less her own $480)

ca_sf_caap.yaml Case 15 is updated to the expectations its own comment predicted once CAPI counted income (budget unit size 2, countable income $2,000, grant $0).

I scanned every YAML case with a noncitizen who is aged, blind, or disabled, and every case that pins is_ssi_eligible_individual. No other expected values should change, and no partner contract test (tests/policy/baseline/partners/**) is affected. I did not run the tests locally; CI will validate them.

Known limitations (not changed here)

  • SSI couple status (ssi_claim_is_joint, is_ssi_eligible_spouse) ignores the noncitizen test. A citizen married to an aged, blind, or disabled noncitizen who fails the test is still treated as an eligible couple, not as an eligible individual with an ineligible spouse (Apply 416.1163(e)(2) to deemed SSI and identify SSI couples by marriage, not tax roles #10141 identifies SSI couples by marriage but keeps the aged/blind/disabled test).
  • The California state supplement still sums countable income over the whole SPM unit for citizen and qualified-noncitizen members; this PR only stops it counting CAPI-eligible members.
  • In Maryland PAA, a couple in which both spouses are aged, blind or disabled still has its combined income halved, even when one spouse fails SSI's noncitizen test.

🤖 Generated with Claude Code

medicaid_optional_senior_or_disabled_countable_income and
ssi_countable_income zeroed income for anyone who was not an SSI-eligible
individual or spouse, and that status includes SSI's citizen and
qualified-noncitizen test. Aged, blind, or disabled people who fail only
that test (for example, LPRs with fewer than 40 quarters, or undocumented
residents of states that cover them) therefore passed the optional ABD and
medically needy Medicaid income tests, and CAPI, regardless of income.

Gate the zero, and the spousal-deeming variables, on aged, blind, or
disabled status instead. The zero still applies to a spouse who is not
aged, blind, or disabled, whose income is deemed to the other spouse.
SSI benefits are unchanged because is_ssi_eligible still applies the
noncitizen test.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
…n status

Counting the own income of aged, blind or disabled people who fail SSI's
noncitizen test exposed two downstream defects found in the 2026-10-19
review:

- The California state supplement summed ssi_countable_income over the whole
  SPM unit, so a CAPI-eligible relative's income reduced an SSI recipient's
  supplement. CAPI budgets its own members' income (MPP 49-035), and SSI/SSP
  counts another member's income only when it is deemed (20 CFR
  416.1160(a)), so CAPI-eligible members are left out of the sum.
- Maryland PAA deemed spouse income and imputed federal SSI to people SSA
  cannot pay. For people who fail SSI's citizen or qualified-noncitizen
  test, PAA now counts only their own income and imputes no SSI (COMAR
  07.03.07.07 and 07.03.07.09A).

The CAPI test that encoded the federal-benefit-only standard is replaced
with an over-income case that holds before and after the CAPI rework.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>

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