[PavelMakarchuk]

Summary

Follow-up to #10279 (merged), which added the shared gov.hhs.liheap.fpg_floor parameter. This branch now has main merged in, so the diff shows only the changes below.

This PR applies the 110% poverty floor of 42 U.S.C. 8624(b)(2)(B) to the three remaining programs whose limits fall below it, as found in the #10279 audit:

Program	Floor binds from (size, by year)	Example: limit vs floor
Indiana EAP (in_eap_eligible)	2025: 15; 2026: 16; 2027: 16	size 16, PY2026: $104,543 vs $107,965
Maryland MEAP (md_meap_eligible)	2025: 29; 2026: 29; 2027: 29	size 29, FY26: $185,864 vs $186,615
Riverside County LIHEAP (ca_riv_liheap_eligible)	2025: 20; 2026: 21; 2027: 21	size 21, FY2026: $136,088.93 vs $138,215

Each formula follows the #10279 pattern: (income <= limit) | (income < round(1.1 x FPG(size, lagged year), 2)). The guideline is the one that HHS makes mandatory on October 1 of the program year, so model year Y uses the January Y-1 guidelines.

• Indiana: new gov.states.in.ihcda.eap.eligibility.fpg_year_lag (1 year), with in_eap_household_size.
• Maryland: reuses md_meap_fpg, which already uses the guideline of the calendar year before the model year. Categorical eligibility still waives the income test.
• Riverside County: new gov.local.ca.riv.cap.liheap.fpg_year_lag (1 year), with spm_unit_size. California's own printed CSD tables also fall below the floor: at sizes 20-25 in the 2025 table (2025 Final Plan, PDF page 180; size 20 tops out at $10,607.47 a month against a $10,750.67 monthly floor) and at sizes 21-25 in the 2026 table (2026 Final Plan, PDF page 184; size 20 at $11,148.47 is still above the $11,013.75 floor).

Payment effects

• Indiana: a floor-only household is above the middle income band and receives the higher-income award. For natural gas heat with an electric bill, that is 6 points x $25 + $50 = $200.
• Maryland: the payment level follows income / FPG, so a floor-only household (below 110% of the guideline) is at Level 4. That pays $360 for gas in FY26.
• Riverside County: the model has eligibility only, with no Riverside LIHEAP payment variable, so there is no payment test.

Tests

For each program:

• One cent below, exactly at, and above the floor.
• A control household one person smaller, where the 60% SMI limit still applies.
• A lag test with income between the lagged floor and the floor from the current year's guidelines.
• Floor boundaries in a second year (2025, with the 2024 guidelines).

Payment tests for a floor-only household:

• in_eap.yaml Case 17: $200, and $0 at the floor.
• md_meap.yaml Case 15: $360, and $0 at the floor.

policyengine-core test on the IN EAP, MD MEAP and Riverside folders: 158 passed. The parameter and reference URL checks also pass. No partner contract tests read these variables.

Not in this PR

• A shared floor helper next to liheap_smi_limit to replace the copies of the floor expression.
• One federal guideline-lag parameter beside fpg_floor in place of the per-state fpg_year_lag parameters.

axiom: 42 U.S.C. 8624(b)(2)(B) in Indiana EAP → TheAxiomFoundation/rulespec-us#1468 queued; in Maryland MEAP → TheAxiomFoundation/rulespec-us#1482 queued; in Riverside County LIHEAP → TheAxiomFoundation/rulespec-us#1840 queued (all blocked on release admission of the signed 42 U.S.C. chapter 94 scope and ingest of the 2024-2025 poverty guideline tables)

🤖 Generated with Claude Code

[hua7450]

Approving. I checked the three floors against 42 U.S.C. 8624(b)(2)(B), the HHS poverty guideline memoranda, the Indiana PY2026 manual, the Maryland FY2026 OHEP guidelines and the CSD 2025 and 2026 plans, and recomputed every new case by hand.

• Pattern. The formulas match 10279. Each uses a strict < against np.round(guideline * fpg_floor, 2) ("less than 110 percent"), ORed with the program's own <= limit, so only the income test is relaxed. Each floor uses the same household size and annual income basis as the program's existing limit: in_eap_household_size, md_meap_household_size through md_meap_fpg, and spm_unit_size as in hhs_smi.
• Guideline year. The year is right for all three. Model year 2026 reads the 2025 guidelines, which HHS made mandatory for FY26 (IM 2025-02, Attachment 2). CSD's own tables show the same one-year lag: the 2026 table tops group 1 for one person at $1,304.17, which is 15,650 / 12.
• Binding sizes. The sizes in the comments and the body recompute: Indiana 15 / 16 / 16, Maryland 29, and Riverside 20 / 21 / 21 for 2025 / 2026 / 2027. The floors match HHS's own 110% tables: 83,765 plus 6,050 per member above 12 under the 2025 guidelines, so 107,965 at size 16 and 186,615 at size 29.
• Payments. Indiana's (2 + 3 + 1) × $25 + $50 = $200 and Maryland's Level 4 gas payment of $360 both recompute. No existing case flips, and no partner test reads these variables.

Nits, none blocking:

1. The Indiana fpg_year_lag description says "under the Low Income Home Energy Assistance Program". The other parameters in gov.states.in.ihcda.eap say "under the Energy Assistance Program".
2. The Riverside fpg_year_lag starts 2021-10-01, but its dated references start with FY25 (IM 2024-02). Either date it 2024-10-01 like Indiana and Oregon, or cite the FY22-FY24 memoranda.
3. In ca_riv_liheap_eligible.py, the comments "(PDF page 180)" and "(PDF page 184)" repeat the page already in each href fragment. Keep just the description.
4. The lag comments say HHS makes the guidelines mandatory "from the next October 1". The memoranda say October 1 or the start of the grantee's fiscal year, whichever is later. Nothing changes here, since Indiana and CSD both run on the federal fiscal year.
5. A household that qualifies only through the floor has income above 60% SMI. IHCDA's matrix has no column above that, so in_eap scores the household in the 45-60% column through the select default. That reading appears only in the Case 17 comment; a one-line note in in_eap.py or in_eap_eligible.py would help.
6. Optional: add 2027 boundary pairs, since the comments state 2027 binding sizes. Indiana size 16: 111,275.99 and 111,276. Maryland size 29: 192,499.99 and 192,500. Riverside size 21: 142,515.99 and 142,516.

Follow-ups for separate PRs:

• The two new lag files are the fifth and sixth copies of the same federal one-year lag (after DC, MS, NJ and OR from 10279), and the floor expression now appears in eight formulas. The gov.hhs.liheap.fpg_year_lag parameter and floor helper you listed would remove both.
• Riverside has no CalFresh or CalWORKs categorical eligibility, although CSD's table pays categorically eligible households that are over income (2026 plan). This predates the PR.