[hua7450]

Adds Arizona's LIHEAP Standard benefit for FY2026. Arizona pays one annual benefit toward all home energy bills, and the plan's heating and cooling components are funding shares of that benefit, so the model treats it as the regular benefit. It counts citizens and qualified noncitizens for household size and counts the gross income of members 18 and over plus Cash Assistance, with each source floored at zero and members' Medicare Part B premiums subtracted. It tests that income against the greater of 60% of state median income and 150% of the 2025 poverty guideline or admits SNAP and Cash Assistance households, requires an energy bill or utilities in rent, scores the Eligibility Worksheet's income, energy-burden and energy-need points and pays $160, $320, $480 or $640. In FY2026, a single 40-year-old earning $30,576 with an $1,800 electric bill receives $160: income at 90.8% of the $33,684 limit gives 1 point, a 5.9% energy burden gives 1 point, and 2 points fall in the $160 band.

Fixes #10290

Regulatory authority

• Arizona DES LIHEAP Policy, revision 16A effective July 1, 2026, pages 3 to 10, 13 to 14, 31 to 35 and 39 to 41, including the FY2027 Appendix A on page 39 and the benefit matrix in Appendix B on pages 40 to 41
• Arizona DES LIHEAP Policy, revision 13 effective August 25, 2025, Wayback capture of October 30, 2025: the FY2026 Appendix A on page 37 and the under-18 income sentence on page 9, which later revisions replaced
• LIHEAP Eligibility Worksheet, $640 limit, effective October 12, 2024, as the Clearinghouse FY2026 matrix
• Arizona FY2026 LIHEAP Detailed Model Plan, pages 4 to 7 and 9 to 10
• DES LIHEAP program page: income-ratio formula, worked examples, point and payment tables
• Clearinghouse FFY2026 Arizona 60% state median income table

Eligibility

Requirement	Source	How modeled
Arizona residence	Policy page 7	defined_for = StateCode.AZ
At least one citizen or qualified noncitizen; only eligible members count toward size; every adult's income counts	Policy pages 4 to 8	az_liheap_household_size adds is_citizen_or_legal_immigrant; a household with no counted member is ineligible
Gross income at or below the greater of 60% SMI and 150% FPG; Appendix A monthly table	Policy page 8; revision 13 Appendix A (page 37); plan section 2.1	az_liheap_income_limit reproduces all twelve FY2026 Appendix A cells ($2,807 to $9,518 a month) and the $687 increment above twelve persons, using the shared liheap_smi_limit helper for the SMI arm and fpg(..., year_lag=1) for the FPG arm with the published floor order
Categorical eligibility through DES Cash Assistance or SNAP	Policy pages 7 to 8; plan question 1.4	az_liheap_categorically_eligible from receipt of snap or tanf; both are take-up gated, and tanf includes Arizona Cash Assistance
Energy-related expense required; renters with utilities in rent qualify	Policy pages 5, 6 and 33; plan page 9	az_liheap_energy_cost adds the seven bill inputs, or heat_expense_included_in_rent
Heating fuel	Worksheet section 2	heating_type UNSPECIFIED pays nothing; NONE stays eligible because the benefit covers every home energy bill

Countable income

Item	Source	How modeled
Members 18 and over	Policy page 9 E, revisions 13 and 16A	az_liheap_countable_earned_income and az_liheap_countable_unearned_income count members aged 18 or older. Revision 15, effective March 23, 2026, narrowed the exclusion to the earned income of members under 18, and revision 16A keeps that wording. A dated boolean counts children's unearned income from March 23, 2026, an inference from the narrowed exclusion.
Earned income	Policy pages 8 and 13 to 14	Wages and net self-employment, farm and partnership or S corporation income, each floored at zero
Unearned income	Policy pages 4, 9 and 14; plan section 1.9	Social Security (gross at the person level), SSI, pensions, military retirement and survivor pay, retirement distributions, railroad retirement, veterans benefits, unemployment, strike benefits, employment disability benefits, workers' compensation, child support received, alimony, rental and farm rental income, gambling winnings, interest, ordinary dividends and general assistance. Each source is floored at zero per person: Gross Income is income "before taxes and other deductions" (page 4), and a loss is not income, so a rental loss offsets nothing.
Medicare premium	Policy page 14 (VII.A.1.c.ii.D note); plan section 1.9	The policy says "Expenses related to Medicare (such as premiums) should be subtracted when determining gross income", and plan 1.9 checks "Excluding MediCare deduction". az_liheap_countable_income subtracts the sum of members' medicare_part_a_premium and medicare_part_b_premium from household gross income and floors the result at zero, so a premium comes off household income whatever the member's income source. Each premium is zero for a person not enrolled in Medicare and excludes any share a Medicare Savings Program pays; the Part A premium is also zero for premium-free Part A, which about 99% of enrollees have. A 67-year-old with $34,000 of Social Security pays the 2026 standard premium of $2,434.80 (12 × $202.90) and counts $31,565.20, under the $33,684 limit. Income at 93.7% of the limit gives 1 point, a 5.7% burden on an $1,800 electric bill gives 1 point and the elderly point makes 3, so the household receives $160; without the deduction, its income would be over the limit. A 67-year-old with a $24,000 pension and no Social Security counts $21,565.20.
Cash Assistance	Policy pages 9 and 32	The take-up-gated tanf, added once per household
Excluded receipts	Plan section 1.9	SNAP and housing assistance are not counted.
Gambling profits	Policy page 9; plan section 1.9	Section VI.A.6.e.ii.B counts "gambling profits", so each member's gambling_winnings less gambling_losses, floored at zero, counts; losses offset winnings but no other income. Plan 1.9 leaves one-time lump sums such as "winnings from lotteries" unchecked; the inputs do not separate one-time winnings, so all profits count.
Railroad retirement, disability and workers' compensation	Policy pages 4, 9 and 14; plan section 1.9	Railroad retirement counts as "retirement income" (section VI.A.6.e.ii.B) and plan 1.9 checks "Retirement / pension benefits". Employment disability benefits count because plan 1.9 checks "Insurance payments made directly to the insured". Workers' compensation counts through the Gross Income definition and "Consistent income received from other sources" (section VI.A.6.e.ii.D); plan 1.9 neither lists nor excludes it.

Benefit

• Income points (worksheet section 1): 5 for income up to 20% of the limit, then 4, 3, 2 and 1 for each further 20%, with inclusive band tops and the ratio formed in float64 before the lookup.
• Energy-burden points (worksheet section 2): 0 to 6 as energy cost over income rises through 5%, 10%, 15%, 20%, 25% and 30%, plus 2 for propane, wood or coal. A household with no income and a bill takes the top band. A household with no bill takes zero, even with no income: a single adult with no income and energy in rent scores 5 income points and 0 burden points and receives $320.
• Energy-need points (worksheet section 3): one each for a member aged 60 or older, a disabled member (is_disabled, SSI paid on the basis of blindness or disability, or Social Security disability receipt), a veteran (is_veteran) and a child aged 6 or under.
• Payment (worksheet section 4; plan section 2.6; policy pages 31, 35 and 41): $160 for 1 to 4 points, $320 for 5 to 8, $480 for 9 to 12 and $640 for 13 or more. The bill does not cap the award. A categorically eligible household above the limit with zero points receives $160, reconciling the plan's $160 minimum with a worksheet whose first row starts at 1 point; this is a reconciliation, not an express rule.
• Revision 16A Appendix B (pages 40 to 41) prints the same four tables as the worksheet.

Years covered

Model year	Program year and policy	Guideline	One-person annual limit
2026	FY2026, revision 13 Appendix A	2025	$33,684
2027	FY2027, revision 16A Appendix A; reproduced, not claimed	2026	$35,232

The registry entry records verified_years: "2026". To keep the three wave 1C PRs from editing the same line, #10303 adds IA, AZ and VA to the LIHEAP coverage line, so it merges last. Parameters are read at the period start, so model year 2026 applies revision 13 and model year 2027 applies the under-18 rule of revision 15, which revision 16A keeps. Revision 16A's Appendix A prints the FY2027 limits ($2,936 to $9,805 a month, plus $710 per additional person), and the model reproduces every cell for period 2027 from the FY2027 state median income and the 2026 guideline; integration Case 6 checks the two-person limit. Revision 16A applies the new limits from its July 1, 2026 effective date, while model year 2026 uses the FY2026 limits all year under the annual convention.

Not modeled and source conflicts

• Annual amounts stand for twelve times the policy's 30-day income snapshot.
• The disability definition (policy page 4) treats "a recipient of benefits under Title II or XVI of the Social Security Act, or other State-administered disability benefits" as disabled. The model reads Title II and XVI as disability benefits: Social Security disability, and SSI paid on the basis of blindness or disability (is_blind or is_ssi_disabled). A retirement or survivor beneficiary, or an SSI recipient who qualifies by age alone, gets the point only with another disability flag.
• Medicare expenses other than the Part A and Part B premiums, such as Part D premiums, have no input and are not subtracted.
• Revision 16A limits Portable Fuel to fuel "used for heating or cooling a residence" (page 5) and makes other uses ineligible (page 7). The bill inputs do not separate uses, so the model counts each fuel bill in full.
• The subsidized-housing utility allowance exclusion, the Tribal LIHEAP first-apply rule, the bar on costs paid by another program, the SUAP $640 recertification maximum and the per-vendor $5 payment rule have no inputs and are not modeled.

Test plan

• 13 YAML files with 127 cases under policyengine_us/tests/policy/baseline/gov/states/az/des/liheap/; expected values are hand computed from the policy, the worksheet and the DES examples in case comments. All 127 cases pass locally on the head, as do the registry and code-health tests.
• The cases cover the Medicare premium deduction (countable income Cases 3 and 4, and Case 5 for a Part A premium; integration Case 2, where a 70-year-old SNAP recipient with propane heat and $36,000 of Social Security counts $33,565.20 and receives $320; railroad retirees in countable unearned Case 7 and az_liheap.yaml Case 14), the rental-loss floor (countable unearned Case 12: $36,000 of wages and a $6,000 rental loss leave the household over the limit, so it receives $0), farm rent and gambling winnings (countable unearned Case 13), military retirement and survivor pay (Cases 10 and 11) and the zero-cost burden rule (energy burden Case 18).
• YAML tests whose expected values come from an external source (statute, official form or worksheet, official calculator)
• make format
• Changelog fragment in changelog.d/

axiom: TheAxiomFoundation/rulespec-us#1833 queued

🤖 Generated with Claude Code

[codecov]

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 100.00%. Comparing base (909176a) to head (e010083).
⚠️ Report is 670 commits behind head on main.

Additional details and impacted files

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[DTrim99]

PR Review: Add Arizona LIHEAP Standard benefit

PR #10293 (author: hua7450), head eff47474a3. This is a first review. The PR adds Arizona's LIHEAP Standard benefit for FY2026: 16 parameters, 14 variables, 13 test files (119 cases), a programs.yaml entry and a changelog fragment. The only comment on the PR is from Codecov. It touches no partner test file.

Path prefixes:

• P/ = policyengine_us/parameters/gov/states/az/des/liheap/
• V/ = policyengine_us/variables/gov/states/az/des/liheap/
• T/ = policyengine_us/tests/policy/baseline/gov/states/az/des/liheap/

Sources read for this review:

• DES LIHEAP Policy, revision 13 (effective 08/25/2025, 37 pages): the Wayback capture of 2025-10-30, pages 3–10, 13–14, 30–34 and 37.
• DES LIHEAP Policy, revision 16A (effective 07/01/2026, 41 pages): the live file, which the PR links. I read all of it, including Appendix A (p. 39) and Appendix B (pp. 40–41).
• Eligibility Worksheet, $640 Limit (effective 10/12/2024): the Clearinghouse FY2026 matrix.
• FY2026 state plan: the Clearinghouse copy. I rendered pages 5, 6, 7, 9 and 10 to read the checkboxes.
• DES program page: des.az.gov/liheap, fetched 2026-10-21.
• FY2027: the Clearinghouse has no Arizona FY2027 plan or matrix (404 on 2026-10-21).

Summary

What is right. The published FY2026 rules are encoded faithfully, and the tests are thorough:

• Income limits. The SMI and FPG arms, with the shared liheap_smi_limit helper and fpg(..., year_lag=1), reproduce all 12 Appendix A cells and the +$687 step (revision 13, p. 37). They also reproduce all 12 FY27 cells and the +$710 step in revision 16A (p. 39).
• Points and payment. The income, energy-burden, portable-fuel and energy-need tables and the $160 / $320 / $480 / $640 bands all match the worksheet, the program page and revision 16A Appendix B.
• Eligibility. Mixed-status household size, categorical eligibility through SNAP or Cash Assistance, the at-or-below test, energy-in-rent households and the under-18 rules of revisions 13 and 15 all follow the policy.
• Tests. Every one of the 23 income-source entries takes a nonzero value in some case. I hand-checked 15 cases, and CI passed all 119.
• Batch checks. The PR reads total_unemployment_compensation (Integrate modeled state unemployment insurance into income flows #9558) and military_retirement_income (Wire military retirement pay and survivors into federal and state tax (#10181) #10182), with the survivor input pinned. Its comments pass the source-conflict ratchet on the merged tree.

There are no critical findings and five should-address items:

• S1. Medicare premiums. Social Security counts gross. Policy VII.A.1.c.ii.D and plan item 1.9 ("Excluding MediCare deduction", checked) both subtract the Medicare premium. medicare_part_b_premium exists, and eight merged LIHEAP states subtract it. Example: a 67-year-old with $34,000 of Social Security gets $0 at the head and $160 under the rule.
• S2. Rental losses. A rental loss offsets wages, although the PR floors every self-employment loss. Example: $36,000 of wages and a $6,000 rental loss get $160 instead of $0.
• S3. Policy page anchors. The policy references cite revision 13 page numbers on the live URL, which has served revision 16A since July 2026. At that link, the Appendix A anchor (#page=37) opens the Welfare Fraud section, and the payment anchor (#page=30) opens voter-registration training.
• S4. Stale Axiom issue. rulespec-us#1833 is open, labelled pe-parity and dispatch-ready. It describes an older head, though: it lists raw unemployment_compensation, omits military_retirement_income, and counts 117 cases.
• S5. One unpinned branch. No test would fail if the zero-cost energy-burden guard were removed. Without it, a zero-income household with energy in rent would get 6 burden points.

There are also six suggestions. They include take-up handling (az_tanf is not take-up gated; tanf is, and nine merged states use it) and the published FY2027 table.

Status.

• CI: 19 checks pass and 10 are still pending (nine contrib shards and Rest (Python + variables)); none has failed. The 119 Arizona cases passed in states-shard-4.
• Branch: 10 commits ahead of main and 2 behind, and it merges cleanly.
• Siblings: the 11 open LIHEAP sibling PRs conflict only in programs.yaml.

Critical (must fix)

None.

Should address

S1. Medicare premiums are not subtracted: Social Security counts gross, although the policy and plan both subtract the premium

• Where:
  • P/income/sources/unearned.yaml:11-13: "Social Security is counted gross here; the premium netting is deferred, as in the other state LIHEAP implementations."
  • The V/income/az_liheap_countable_unearned_income.py documentation, the T/income/az_liheap_countable_unearned_income.yaml header ("deferred, as in Kansas") and the PR body's not-modeled list ("deferred as in Kansas") say the same.
• Sources:
  • Policy VII.A.1.c.ii.D (revision 13 p. 14; unchanged in revision 16A p. 14): "Social Security, Veterans Administration, or retirement benefits; Note: Expenses related to Medicare (such as premiums) should be subtracted when determining gross income."
  • FY2026 plan item 1.9 (p. 6, rendered): "Social Security Administration (SSA) benefits" is checked, with "Excluding MediCare deduction" checked and "Including MediCare deduction" unchecked.
• Why the stated precedent does not hold:
  • medicare_part_b_premium (person, annual) is on main. It holds the out-of-pocket Part B premium, net of Medicare Savings Program (MSP) coverage, and it is zero for non-enrollees.
  • Merged IN, KY, MD, NJ, NY, OH, RI and SD LIHEAP subtract it.
  • Kansas counts Social Security gross because Kansas's own rule includes the Medicare deduction ("SSA benefits are counted gross, including the Medicare deduction"). Arizona's rule is the opposite.
• Effect (hand-traced from the code for 2026). Take a single person aged 67 with $34,000 a year of Social Security, electric heat and a $1,800 bill. Income of $2,833 a month is well above the 135% QI limit, so MSP pays nothing. The premium is 12 × $202.90 = $2,434.80.
  • Head: 34,000 > 33,684, so $0.
  • Rule: 34,000 − 2,434.80 = 31,565.20 ≤ 33,684, so the household is eligible. 93.7% gives 1 income point and 5.7% gives 1 burden point. With the elderly point that is 3 points, or $160.
  • Within the limit. With $22,500 of Social Security and a $2,100 bill, the head gives 2 + 1 + 1 = 4 points ($160). The rule gives 59.6% (3 points) and 10.5% (2 points): 6 points, $320.
  • Existing case. Integration Case 2 (Social Security $36,000, SNAP, propane) would move from $160 to $320: income 33,565.20 gives 1 point, burden 8.0% gives 1 + 2, and elderly gives 1. The Axiom issue's interpretation 9 reaches the same number.
• Severity: should, as in Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 S1 (Virginia) and wave 1 (Add New Jersey LIHEAP regular heating assistance #9745 S1, Add New York HEAP regular heating assistance #9744 S1).
• Fix:
  • Subtract each member's medicare_part_b_premium from gross income, either as a deductions list like Ohio's or in the formula like New Jersey's. Floor the result per person.
  • Replace the three comments and the body row. Keep Part D as not modeled, since it has no separate input.
  • Add a case like the first example, and update integration Case 2 and countable-unearned Case 1.

S2. Rental losses offset wages and other income

• Where:
  • V/income/az_liheap_countable_unearned_income.py:28 sums p.sources.unearned with add(), keeping signs. That list includes rental_income (P/income/sources/unearned.yaml:31).
  • V/income/az_liheap_countable_income.py adds the person totals without a floor.
  • The PR's own earned rule (P/income/sources/earned.yaml:6-9, and the documentation of az_liheap_countable_earned_income) floors each self-employment source "so a business loss does not offset other earnings".
• Sources:
  • Gross Income is "The total Household income for all Household members before taxes and other deductions" (policy p. 4, both revisions). A loss is not income.
  • Plan item 1.9 checks "Rental income" (p. 6). Neither the plan nor the policy lets a loss in one source reduce another.
• Effect (hand-traced for 2026). A single person aged 40 has $36,000 of wages and a $6,000 rental loss, with electric heat and a $1,800 bill.
  • Head: countable income is 30,000, or 89.1% of the limit: 1 income point and 1 burden point (6.0%), 2 points, $160.
  • With the loss floored: 36,000 > 33,684, so $0.
• Tests: no case sets a negative rental_income.
• Severity: should, as in Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 S2 (Virginia) and Add New Jersey LIHEAP regular heating assistance #9745 S2 (New Jersey).
• Fix:
  • Floor rental_income per person. Either move it into the floored loop or floor each unearned entry.
  • Add a rental-loss case like the one above.

S3. The policy references cite revision 13 pages on a URL that now serves revision 16A

• What happened. Every policy href points to https://des.az.gov/sites/default/files/dl/CCSD-LIHEAP-Policy.pdf. Its titles name revision 13 and use revision 13's page numbers. That URL has served revision 16A (41 pages) since July 1, 2026.

  • Revision 16A shifts the back half of the document by one or two pages.
  • Its Appendix A prints the FY27 limits, not the FY2026 values the PR encodes.
  • The PR body says the direct download is blocked. On 2026-10-21 it returned HTTP 200 to a generic browser User-Agent.

• Anchors that do not show their value at the link:

  Reference	Cited (revision 13 page)	What the live link opens	Revision 16A page
  P/eligibility/fpg_year_lag.yaml, P/eligibility/max_table_size.yaml	Appendix A, #page=37	VII.D–E, monitoring and Welfare Fraud	39 (FY27 table)
  P/payment/amount.yaml	VII.B.1.a and VII.B.4.b, #page 30,34	voter-registration training (p. 30)	31 and 35
  P/income/sources/unearned.yaml	VI.A.6.e.ii.B–D within #page 4,8,13-14	p. 8 has the eligibility rules; B–D are on p. 9	4, 9, 14
  V/az_liheap.py comment	"PDF pages 10, 29-30, 33-34"		10, 31, 34–35
  V/eligibility/az_liheap_eligible.py comment	VII.B.3.a.ii.B, "32"		33
  V/eligibility/az_liheap_income_eligible.py, az_liheap_income_limit.py comments	Appendix A, "37"		39
  V/income/az_liheap_countable_income.py comment	VII.B.1.c, "31"		32

  Test headers repeat #page=37 and #page=33.

• Which anchors are right. pp. 3–5 (definitions), 8 (VI.A.6.c–d), 9 (VI.A.6.e.ii.E) and 10 (VI.B.1) fall on the same pages in both revisions.

• Severity: should (checklist item 7: wrong anchors).

• Fix:

  • Point each revision 13 citation at a Wayback capture, keeping its page numbers. Use https://web.archive.org/web/20251030203752/https://des.az.gov/sites/default/files/dl/CCSD-LIHEAP-Policy.pdf#page=37, or the 2025-10-17 capture that rulespec-us#1833 uses.
  • Point the revision 15 citation for child_unearned_income_counted at its own capture.
  • Add revision 16A (the live URL) as a separate reference where the period 2027 values depend on it: p. 39 for Appendix A and pp. 40–41 for the matrix. See G5.

S4. rulespec-us#1833 no longer matches the head

• What the issue gets right. It is open, labelled pe-parity and dispatch-ready. It has module paths, corpus status, verbatim law, required outputs, 14 companion tests and its blockers (sources missing from the corpus, bundle scope, an unchecked signed release, billed runs, no reviewed oracle revision).
• Where it is stale. It describes head c12ed6dbd4 (2026-10-20). Two later commits changed the code:
  • cc76cdf244 switched the unearned list to total_unemployment_compensation and pinned az_tanf: 0 in seven cases.
  • 8c9c5f1f8d added military_retirement_income and two cases.
• The resulting gaps:
  • The required-outputs row for countable unearned income still names raw unemployment_compensation, which the Integrate modeled state unemployment insurance into income flows #9558 guard now rejects. It lists 16 sources, while the head has 18, without military_retirement_income.
  • The test inventory says 117 cases; the head has 119.
  • No companion test covers military retirement pay or the Survivor Benefit Plan (SBP) annuity.
• Severity: should (checklist item 9: stale companion values).
• Fix: update the issue to the final head after S1 and S2. Name medicare_part_b_premium and the rental floor in the required outputs, revise interpretation 9 and companion test 8(a) ($320), and add the military-retirement and SBP rows.

S5. The zero-cost energy-burden branch has no test

• Where: V/points/az_liheap_energy_burden_points.py:40, burden = where(cost > 0, burden, 0).
• What it does. With zero income, the division yields infinity. This line is what gives a household with no bill 0 burden points rather than 6. The PR body states that rule: "a household with no bill takes zero".
• Why it is unpinned. Every zero-cost case has positive income: burden Case 11 has $12,000, integration Case 4 has $4,164 and eligibility Case 4 has $30,576. In those cases the line changes nothing. No test would fail if it were deleted, yet a zero-income household with energy in rent would then score 5 + 6 = 11 points ($480) instead of 5 ($320).
• Severity: should, as in Add Alabama LIHEAP regular heating assistance #9967 S3 (Alabama) and Add Oklahoma LIHEAP regular heating assistance #9970 S6 (Oklahoma): checklist item 13.
• Fix: add a case with no income, heat_expense_included_in_rent: true and no bills. Expect 0 burden points, 5 points and $320 for a single adult.

Suggestions

G1. Count TANF through the take-up-gated tanf.

• The head. P/eligibility/categorical_programs.yaml lists az_tanf, and V/income/az_liheap_countable_income.py adds az_tanf. az_tanf is the computed benefit with no take-up gate. tanf (defined_for = "takes_up_tanf_if_eligible") is gated, as is snap.
• The merged states. AL, FL, KY, MD, NJ, OK, OR, RI and SD all read tanf; only Kansas reads ks_tanf.
• The effect. In microsimulation, a TANF-eligible family that does not take up TANF is treated as enrolled, and a benefit it does not receive is counted as income. Household runs are unaffected, since take-up defaults to true. Such families are far below the limit, so only income points can move.
• The Axiom issue. Its interpretation 7 already records the gap.
• Fix: swap az_tanf for tanf in both places.
• A note on the seven az_tanf: 0 pins. These cases need the pin because main's TANF earned income reads employment_income_before_lsr, which these tests leave unset. That is a test-input convention on main, not a defect in this PR.

G2. A heat-in-rent household with UNSPECIFIED fuel.

• The input convention. main's heating_type documentation says UNSPECIFIED "is also the right value when heat is included in rent and the fuel is unknown". The head makes that household ineligible (V/eligibility/az_liheap_eligible.py:44).
• Merged practice. Florida and Mississippi admit heat_in_rent | (heating_type != UNSPECIFIED).
• Why it fits Arizona. The benefit depends on the fuel only through the +2 portable-fuel points.
• Fix: consider known_fuel | heat_in_rent, as in Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 G2.

G3. The subsidized-housing allowance test can use hud_utility_allowance.

• The rule. Policy VI.A.2 (revision 13 p. 6) bars an applicant in subsidized housing whose utility allowance is "greater than or equal to" the monthly energy cost. Plan 2.3 (p. 9) says "exceeds".
• The head. The PR says the test has no input.
• The input. Merged Alabama reads hud_utility_allowance, which a user can supply. It returns 0 for Arizona counties, so microsimulation would not change.
• Fix: consider allowance > 0 & allowance >= cost / 12 as an exclusion, and record the "or equal" choice.

G4. Two income sources are missing.

• Gambling. Policy VI.A.6.e.ii.B names "gambling profits" (revision 13 p. 8), and gambling_winnings exists on main. Plan 1.9 leaves "winnings from lotteries" unchecked, but only as a one-time lump sum. The PR's list of sources with "no model input" omits gambling without comment. Either count it or record the choice in P/income/sources/unearned.yaml.
• Farm rent. Plan 1.9 checks "Rental income", and farm_rent_income exists. Merged Kansas and Virginia count it. Add it beside rental_income, floored per S2.

G5. FY2027 is already published, and the July 1 switch is undocumented.

• The published table. Revision 16A prints the FY27 limits in Appendix A (p. 39) and an unchanged matrix in Appendix B (pp. 40–41).
• The model reproduces it. Period 2027 gives every cell:
  • floor(0.6 × 112,946) = 67,767;
  • sizes 1–9 at 2,936, 3,840, 4,743, 5,647, 6,550, 7,454, 7,623, 7,793 and 7,962;
  • sizes 10–12 from 1.5 × the 2026 guideline: 8,385, 9,095 and 9,805;
  • +710 above 12.
• Only one case pins it. Integration Case 6 checks size 2 and calls it "not independently verified policy". The body says 2027 is "unverified against a published FY2027 matrix".
• Fix:
  • Consider a 2027 grid case for sizes 1–14 and the revision 16A reference (S3).
  • Either set verified_years: "2026-2027" or keep 2026 and correct the two statements.
  • Note the timing in the body or the az_liheap documentation. The program page says the limits apply "As of July 1st, 2026", inside FY2026. Model year 2026 uses the FY2026 limits all year, by the annual convention. The Axiom issue's interpretation 17 records this; the PR does not.

G6. Small test and polish items.

• A mixed-state case. No case runs an Arizona and a non-Arizona SPM unit in one simulation (item 15). It is safe today: az_liheap_household_size (int, default 0) feeds only clip(), smi_size_factor() arithmetic and where(), never a parameter key. A mixed case would keep it pinned.
• A stray reference. T/income/az_liheap_countable_unearned_income.yaml Case 4 says "(contract R1)", an internal reference.
• The registry. AZ is inserted between IL and IN in the LIHEAP state_implementations list and the coverage line. Neither list is fully sorted, so this is cosmetic.

Verified correct

Values against sources:

• Income limit (VI.A.6.c.i, revision 13 p. 8; Appendix A p. 37; plan 2.1 p. 9):
  • floor(0.6 × 107,983) = 64,789. The SMI arm floor(floor(f × 64,789) / 12) gives 2,807, 3,671, 4,535, 5,399, 6,262, 7,126, 7,288, 7,450 and 7,612 for sizes 1–9.
  • The 2025-guideline arm floor(1.5 × G / 12) gives 8,143, 8,831 and 9,518 for sizes 10–12, and +687 above 12.
  • That is all 12 cells. The crossover at size 10 matches plan 2.1's two rows.
  • The at-or-below test is <=.
• Guideline lag. fpg_year_lag 1 is required: the 2026 guideline would give 8,385 at size 10, not 8,143.
• Points (worksheet sections 1–3; program page; revision 16A pp. 40–41):
  • income bands 5 / 4 / 3 / 2 / 1 at band tops 20 / 40 / 60 / 80 / 100%, and 0 above 100%;
  • burden bands 0–6 at 5 / 10 / 15 / 20 / 25 / 30%;
  • +2 for propane, wood or coal (the Portable Fuel definition, p. 5);
  • one point each for 60+, disability, veteran and age 6 or under, one per category.
  • The right=True reading places the program page's 44% and 17.5% examples correctly, and float64 keeps exact band tops in band.
• Payment (worksheet section 4; plan 2.6 p. 10): $160 / $320 / $480 / $640. The zero-point $160 is a documented reconciliation with plan 2.6's minimum. The award is not capped at the bill: the policy credits any remainder to Priority 1 (VII.B.3.b.iii.D.2).
• Eligibility:
  • Household size. Size counts citizens and qualified noncitizens (VI.A.6.d.i), and every adult's income counts (VI.A.6.d.ii). A unit with no eligible member is ineligible (VI.A.3).
  • Categorical eligibility. SNAP or Cash Assistance only; SSI and veterans programs do not confer it (plan 1.4, p. 5).
  • Energy expense. A bill or energy in rent is required (VI.A.1; "undesignated payments for Energy Utilities in the form of rent", p. 4). NONE with an electric bill stays eligible, because the benefit covers cooling.
• Income:
  • Under-18 rules. Earned income under 18 is never counted. Unearned income under 18 counts from 2026-03-23 (revision 15 narrowed VI.A.6.e.ii.E), and the PR labels that as an inference; plan 1.9 supports it by leaving only "Earned income of a child under the age of 18" unchecked.
  • Sources. Gross wages and per-source floors on self-employment are used. SSI, child support, alimony, interest, dividends, strike pay, VA benefits, general assistance, railroad retirement, retirement distributions, employment disability insurance and workers' compensation all count, as plan 1.9 and VI.A.6.e.ii.B–D require.
  • Cash Assistance is added once (VI.A.6.e.ii.B; VII.B.1.c).
• Documented simplifications:
  • The whole household's income is used for categorically eligible households, not "the reported income of the Household member who is actively enrolled" (VII.B.1.c).
  • The disability point reads Title II and XVI as disability benefits. That is the better reading of "or other State-administered disability benefits".
  • Annual income stands for twelve times the 30-day snapshot.

Hand-checked expectations (15 cases). Annual limits are 33,684 (size 1), 44,052 (size 2) and 54,420 (size 3).

• az_liheap.yaml Case 1: 30,576 / 33,684 = 90.8% (1); 1,800 / 30,576 = 5.9% (1); 2 points, $160.
• az_liheap.yaml Case 4: 21,000 / 54,420 = 38.6% (4); 4,000 / 21,000 = 19.0% (3); child (1); 8 points, $320.
• az_liheap.yaml Case 6: 18.4% (5); 2,400 / 10,000 = 24% (4); elderly, disabled and child (3); 12 points, $480.
• az_liheap.yaml Case 8: 8,400 / 44,052 = 19.1% (5); 3,000 / 8,400 = 35.7% (6 + 2); four categories, with the veteran flag derived from veterans_benefits; 17 points, $640.
• az_liheap.yaml Case 9: SNAP; 118.8% (0); 4.5% (0); 0 points, so $160 from the band keyed at 0.
• az_liheap.yaml Case 10: zero income (5); a $300 bill against zero income (6); 11 points, $480, above the bill.
• Income-limit Case 1: all 14 sizes, including 13 (122,460) and 14 (130,704). Each matches Appendix A × 12.
• Income-eligible Cases 6–7: size 10, 97,716 is eligible and 97,717 is not (FPG arm).
• Income-eligible Case 11: mixed status. Size 2 gives a limit of 44,052, and 48,000 of income from both adults is over it.
• Integration Case 1: 2,000 / 4,535 = 44% (3), the program-page example; 2,400 / 24,000 = 10.0% stays in the 6–10% band (1); child (1); 5 points, $320.
• Integration Case 2: 36,000 / 33,684 = 106.9% (0) with SNAP; 7.5% (1 + 2); elderly (1); 4 points, $160. This becomes $320 under S1.
• Integration Case 4: Cash Assistance of 4,164 / 44,052 = 9.5% (5); energy in rent with no bill (0); child (1); 6 points, $320.
• Integration Case 6 (2027): revision 16A size 2 is 3,840 × 12 = 46,080. 21,600 is 46.9% (3); 9.3% (1); 4 points, $160.
• Countable-unearned Cases 5–6: the child's 11,928 + 4,800 is excluded in 2026 and counted (16,728) in 2027.
• Burden Case 12: 2,700 / 24,000 = 11.25% (2 + 2), 4 points.

Batch checks:

• Integrate modeled state unemployment insurance into income flows #9558: the list reads total_unemployment_compensation, which countable-income Case 2 and unearned Case 2 pin. The four guard tests passed in CI.
• Wire military retirement pay and survivors into federal and state tax (#10181) #10182 (item 16): the list reads military_retirement_income, and unearned Case 11 pins the survivor input.
• Document disjoint health premium inputs and correct consumer treatment #10046 (item 14): not applicable to payroll premiums. Arizona counts gross wages and deducts no health premium other than Medicare (S1).
• State-gated keys (item 15): safe. No state-gated int or enum feeds a parameter key; heating_type is compared, not indexed. The Microsimulation job passed. A mixed-state case is optional (G6).
• Federal 110% floor: never binds. The limit is at least floor(1.5 × the 2025 guideline / 12) × 12 ≥ 1.5g − 12. That is about 1.36 times 1.1 × the 2025 or 2026 guideline at every size: for size 1, $33,684 against $17,556 (2026). Not wiring the floor matches Alabama, Oklahoma and Virginia, the other 150% states.
• IIJA (item 12): not applicable. Arizona pays no separate supplement in the Standard benefit, and no FY2027 plan is posted.
• Source-conflict ratchet (Tie source-conflict markers to the register shared with Axiom #10287):
  • I ran the comment readers and CONFLICT_COMMENT_RE from main's test_source_conflicts.py over the PR's 30 new parameter and variable files. They give 206 comment lines, 0 matches and no marker attempts. The control files, Florida's base_amount.yaml and Kentucky's ky_liheap.py, gave their expected 1 each.
  • In CI, the ratchet passed on the merge with a6fafb06c2. main's two newer commits touch no code-health file.
• Wiring:
  • Registry. The programs.yaml AZ entry is present, and AZ is added to the coverage line. test_programs_registry passed.
  • Aggregates. None, which matches every merged LIHEAP state.
  • Gating. defined_for = StateCode.AZ is on 13 variables, and az_liheap is gated by az_liheap_eligible. test_members_are_state_gated passed.
  • Changelog. changelog.d/az-liheap-wave1c.added.md is top level and typed added.
• Descriptions (item 6): all 16 end "under the Low Income Home Energy Assistance Program".
• References (item 7): the worksheet (p. 1), plan pp. 4, 5, 6–7, 9 and 10, the program page and the Clearinghouse SMI and guideline tables all show their values. Multi-page titles are quoted, and variable tuples use # PDF pages comments. The policy anchors are S3.

Checklist results (LIHEAP batch):

1. State plan and manual: pass for every published cell. FY2026 timing is read on January 1; the July 1 switch is G5.
2. Income definition: fail on two items. The Medicare premium is not subtracted (S1), and rental losses net (S2).
3. Backdating: pass. Earlier years are documented as unverified backfill, and the published FY2027 table is reproduced (G5).
4. Household and arrangement rules: pass. Every branch has a test except the zero-cost guard (S5); the subsidized allowance is G3, and heat in rent with UNSPECIFIED fuel is G2.
5. Tests: 119 cases, 15 hand-checked, periods plain, and all 23 source entries exercised.
6. Descriptions: pass.
7. References: the policy anchors are wrong at the live URL (S3); the rest pass.
8. Wiring: pass, apart from take-up (G1).
9. Axiom: valid but stale (S4).
10. Branch and CI: a clean merge; 19 pass and 10 pending, none failed.
11. Integrate modeled state unemployment insurance into income flows #9558: pass.
12. IIJA / FY2027: not applicable; the FY27 limits are reproduced.
13. Mutation check: one unpinned branch (S5).
14. Document disjoint health premium inputs and correct consumer treatment #10046: not applicable.
15. State-gated index defaults: safe.
16. Wire military retirement pay and survivors into federal and state tax (#10181) #10182: pass.
17. Merged state SSPs: not applicable. main has no Arizona state supplement variable, and the registry's ssi_state_supplement coverage excludes AZ.

• Federal 110% floor: never binds.

Axiom line assessment

Valid but stale: axiom: TheAxiomFoundation/rulespec-us#1833 queued (S4).

• What is in order. The issue is open and labelled enhancement and pe-parity.
  • Blockers. Its "Why queued" section records the editions missing from the corpus (revisions 13 and 15, the worksheet, the program page, the FY2026 SMI table and the 2025 guidelines), the FY2027-only bundle scope, the unchecked signed release, billed-run approval and the lack of a reviewed oracle revision.
  • Content. Its verbatim text matches the sources I read, including plan 1.9's "Excluding MediCare deduction" and both Appendix A tables. Its companion tests are derived from the sources, not from PE output.
• What needs updating:
  • The head SHA, the unearned source list (total_unemployment_compensation and military_retirement_income) and the case count.
  • After S1 and S2: the Medicare subtraction and the rental floor in the required outputs, interpretation 9, and companion test 8(a).

CI status

19 pass, 10 pending, 0 failed. Run 39635438247 tests merge commit 56d2dc78, which merges head eff47474a3 into a6fafb06c2 (pull_request, started 2026-10-21 16:30 UTC). I re-checked gh pr checks 10293 at the end of this review.

• Passed: all four states shards; the household, irs, ssa-usda, rest-a, rest-b, reform and contrib-hhs baseline shards; Rest (Python, shard-1 + variables); Microsimulation; Household API Partners; PR validation; Package and compatibility; Quick Feedback; and both Codecov checks.
• Still pending: nine contrib shards (congress, states 1–4, other 1, 2a, 2b and 3) and Rest (Python + variables). None of them runs the Arizona LIHEAP files.
• Where the Arizona tests ran. States-shard-4 (batch 1/13, states/az) ran all 13 files: 14 + 7 + 5 + 10 + 11 + 3 + 6 + 2 + 11 + 6 + 17 + 15 + 12 = 119 passed.
• Guards. Rest shard-1 passed:
  • the six test_source_conflicts.py structural tests, including the ratchet;
  • the four Integrate modeled state unemployment insurance into income flows #9558 guard tests;
  • test_members_are_state_gated;
  • test_programs_registry.
• Known main-caused failure. Not applicable: the run started after 13:24 UTC, and the ratchet passed.
• Locally: I ran no tests or model probes. The examples in S1, S2 and S5 are hand traces of the code at the head. The only local Python was the static comment scan above, which does not import the model.

Branch status

• Position: 10 commits ahead of main (328d1721e2) and 2 behind. The merge base is a6fafb06c2 (Support state-specific other additions and subtractions for remaining 30 states (Phase 2) #10302). The two newer commits (Count gross unemployment compensation and Social Security in South Carolina TANF #9687, South Carolina TANF, and a version bump) do not touch Arizona LIHEAP or any guard.
• Merge: clean. git merge-tree --write-tree PolicyEngine/main eff47474a3 exits 0.
• Sibling conflicts (branch note). A trial merge with each open LIHEAP PR conflicts only in policyengine_us/programs.yaml, the shared coverage line and state list. The PRs are Add Georgia LIHEAP regular heating assistance #9968 (GA), Add Pennsylvania LIHEAP regular heating assistance #9971 (PA), Add Arkansas LIHEAP regular heating assistance #9973 (AR), Add Iowa LIHEAP regular heating assistance #10292 (IA), Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 (VA), Add Alaska LIHEAP regular heating assistance #10341 (AK), Add North Dakota LIHEAP regular heating assistance #10342 (ND), Add New Hampshire LIHEAP regular heating assistance #10343 (NH), Add Utah LIHEAP regular heating assistance #10344 (UT), Add Washington LIHEAP regular heating assistance #10345 (WA) and Add Wyoming LIHEAP regular heating assistance #10346 (WY). Point the FL and SD LIHEAP conflict candidates at their code on main #10349 merges cleanly. Whichever lands first, the rest need a one-line resolution.

0 critical, 5 should and 6 suggestions are open at this head.

Verdict: REQUEST_CHANGES

[DTrim99]

The Appendix A limits, worksheet points and benefit bands reproduce exactly, and so does the published FY27 table. All 23 income sources are exercised. Five should-address items: (1) the Medicare premium isn't subtracted (Policy VII.A.1.c.ii.D; plan 1.9); (2) rental losses offset wages; (3) the policy-manual anchors cite revision-13 pages on a URL that now serves 16A; (4) rulespec-us#1833 is stale; (5) the zero-cost burden guard is unpinned. Six suggestions, including that the FY27 table is out. Full report in the comment above.

[hua7450]

Thanks, David. The fixes are in 49fa4c2, 004ed27 merges main, and 406a5ef moves the Medicare deduction to household income. All 124 Arizona cases pass locally, as do the registry, source-conflict and unemployment-reader checks.

Should address

• S1, Medicare premium: fixed. The revision 16A note under VII.A.1.c.ii.D (page 14) reads "Expenses related to Medicare (such as premiums) should be subtracted when determining gross income." az_liheap_countable_income now subtracts the members' medicare_part_b_premium from household gross income, floored at zero. Your 67-year-old with $34,000 of Social Security counts $31,565.20 and receives $160 (countable income Case 3). Without the premium as an input, the model computes the same $2,434.80 premium and $160. Countable income Case 4 covers a Medicare member with a pension and no Social Security.
• S2, rental losses: fixed. Every unearned source is now floored at zero per person. $36,000 of wages with a $6,000 rental loss now gets $0 (countable unearned Case 12).
• S3, page anchors: fixed. Policy references now cite revision 16A pages. The FY2026 Appendix A and the earlier under-18 sentence exist only in revision 13, so those cite the October 30, 2025 Wayback copy. No cited value changed in revision 16A. Its new portable fuel use limit (pages 5 and 7) is listed as not modeled.
• S4, Axiom issue: updated. LIHEAP wave 1c: encode Arizona LIHEAP Standard benefit TheAxiomFoundation/rulespec-us#1833 now describes 406a5ef, with the Medicare deduction, the rental floor, farm rent, gambling, tanf, the revision 16A locators and 124 cases.
• S5, zero-cost guard: fixed. Burden points Case 18 has no income, energy in rent and no bills. It scores 0 burden points, and 6 without the guard.

Suggestions

• G1, TANF: taken. The categorical list and countable income read the take-up-gated tanf. The seven pins are now tanf: 0.
• G2, UNSPECIFIED with heat in rent: declined. heating_type is a required input for every state LIHEAP program, and callers send the fuel. The default is tracked in Default heating_type to electricity and remove the UNSPECIFIED-gated state heating adapters #9754.
• G3, hud_utility_allowance: not taken. It returns 0 for Arizona counties, and the body keeps the allowance test as not modeled.
• G4, gambling and farm rent: taken. gambling_winnings and farm_rent_income now count, floored per source (countable unearned Case 13).
• G5, FY2027: statements corrected. The body and integration Case 6 now say that revision 16A prints the FY2027 limits and that the model reproduces them for 2027. 2027 stays unclaimed. The body also covers timing: model year 2026 uses the FY2026 limits all year.
• G6: I removed "(contract R1)". The mixed-state case and registry order are not taken.

[DTrim99]

PR Review (round 2): Add Arizona LIHEAP Standard benefit

PR #10293 (author: hua7450). This round reviews head 406a5efe6a; round 1 reviewed eff47474a3. Three commits came in between:

• 49fa4c2f47, "Fix issues from review: Medicare premium, rental floor, revision 16A anchors". It answers S1–S5 and G1, G4, G5 and G6.
• 004ed274b4, a merge of main at 6a92d6a983. It had one hand-resolved conflict, the LIHEAP coverage line in programs.yaml (checked below). It changes no Arizona LIHEAP file.
• 406a5efe6a, "Deduct Medicare premiums from household gross income". It moves the S1 deduction from Social Security to household gross income.

Ziming replied to every finding on 2026-10-24. The PR body still ends axiom: TheAxiomFoundation/rulespec-us#1833 queued, and the issue has been rewritten for this head. The PR still touches no partner test file.

Path prefixes, as in round 1: P/ = policyengine_us/parameters/gov/states/az/des/liheap/, V/ = policyengine_us/variables/gov/states/az/des/liheap/, T/ = policyengine_us/tests/policy/baseline/gov/states/az/des/liheap/.

Summary

Ziming fixed all five round-1 should items:

• S1, Medicare premiums. V/income/az_liheap_countable_income.py:58-59 subtracts the members' out-of-pocket medicare_part_b_premium from household gross income and floors the result at zero. Social Security counts gross at the person level. Countable income Case 3 reproduces the round-1 example exactly: $160 instead of $0. Integration Case 2 moves from $160 to $320, as round 1 predicted.
• S2, rental losses. Every unearned source is now floored at zero per person (V/income/az_liheap_countable_unearned_income.py:35-37). Countable unearned Case 12 reproduces the round-1 example: $0 instead of $160.
• S3, page anchors. Every policy reference now cites revision 16A pages on the live URL. The FY2026 Appendix A and revision 13's under-18 sentence cite the October 30, 2025 Wayback capture. I re-fetched the live file and every revision 16A anchor shows its provision.
• S4, Axiom issue. rulespec-us#1833 now describes this exact head, including the Medicare deduction, the per-source floors, the 19 unearned sources and 124 cases.
• S5, zero-cost guard. Energy burden Case 18 pins it. Without the guard, that case would score 11 points and $480 instead of 5 points and $320.

Of the six suggestions, three are taken (G1 tanf, G4 farm rent and gambling, G5 the FY2027 statements) and G6 is partly taken. G2 and G3 are declined for reasons I accept.

There are no new critical or should findings, and two new suggestions:

• G7. The policy subtracts "Expenses related to Medicare (such as premiums)", and medicare_part_a_premium exists on main. The body says only that Part D has no input. This matters only for the roughly 1% of enrollees who buy Part A. It is the same item as G7 on the Virginia EAP PR (Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303).
• G8. Two optional refinements:
  • The new household floor has no test. Removing it would change only the reported countable income, not any benefit.
  • "Gambling profits" could be read net of gambling_losses.

Batch checks:

• Integrate modeled state unemployment insurance into income flows #9558 and Count military SBP annuities in state benefit income lists #10317: both guards pass.
• Tie source-conflict markers to the register shared with Axiom #10287 ratchet: passes in CI. A static scan of the 30 Arizona parameter and variable files against main's pattern finds 0 matches, so it also holds on the merged tree.
• Item 15: the state-gated keys are unchanged and safe.
• Item 17: not applicable; main has no Arizona supplement.

I hand-checked every new or changed expectation: 5 new cases, 4 cases with changed expectations, and the pin-only and rename-only edits. CI is 29/29 green at the head, and states-shard-4 passed all 124 Arizona cases. The branch is 34 commits behind main and merges cleanly.

Prior findings status

Finding	Status	Evidence
S1: Social Security counted gross, although Policy VII.A.1.c.ii.D and plan 1.9 subtract the Medicare premium	Fixed	The code. V/income/az_liheap_countable_income.py:42-50 adds countable earned income, countable unearned income and tanf. Line 58 sums medicare_part_b_premium over the members, and line 59 returns max_(gross_income - medicare_premiums, 0). social_security is back in P/income/sources/unearned.yaml:14 and counts gross. The variable. medicare_part_b_premium is person-level and annual, "paid out of pocket by the enrollee, net of Medicare Savings Program coverage", with defined_for = "medicare_enrolled". The round-1 example (hand trace, 2026). A single person aged 67 has $34,000 of Social Security and a $1,800 electric bill. 34,000 − 2,434.80 = 31,565.20 ≤ 33,684, so the household is income eligible. 93.71% gives 1 income point and 5.70% gives 1 burden point. With the elderly point that is 3 points, or $160. Countable income Case 3 pins exactly this. Without the premium input, the model computes the same premium: 12 × $202.90, with no IRMAA, and no MSP help at $2,833 a month against the $1,760.62 QI limit (135% of the 2025 guideline). Household rather than per person. Round 1 suggested flooring per person. The household subtraction fits the policy's "Gross Income: The total Household income for all Household members" (p. 4), matches the approved Virginia EAP approach, and is recorded as Axiom interpretation 9. I accept it. Other coverage. Countable income Case 4 covers a pension with no Social Security, and countable unearned Case 7 and az_liheap.yaml Case 14 cover railroad retirees. The comments. The three "deferred, as in Kansas" comments are gone. The documentation and the body describe the deduction, and Part D stays not modeled (see G7 for Part A).
S2: a rental loss offset wages	Fixed	The code. V/income/az_liheap_countable_unearned_income.py:35-37 floors each source: max_(person(source, period, options=[ADD]), 0). ADD sums the monthly ssi. The round-1 example. Countable unearned Case 12: 36,000 + max(−6,000, 0) = 36,000 > 33,684. There is no SNAP or TANF, so the household is not eligible and gets $0. Farm rent. It is floored the same way and is positive in Case 13.
S3: revision 13 page numbers on a URL that serves revision 16A	Fixed	The live file. des.az.gov still serves revision 16A: 41 pages, "Effective Date: 07/01/2026", byte-identical to the copy the Axiom issue locks. Revision 16A anchors I confirmed: Categorical Eligibility pp. 3–4; Gross Income, Disability and Energy Utility p. 4; Household, Portable Fuel and Qualified Noncitizen p. 5; VI.A.3 and the new Portable Fuel use limit p. 7; VI.A.6.c–d and e.ii.A p. 8; VI.A.6.e.ii.B–E p. 9; VI.B.1 p. 10; VII.A.1.c.ii.A–B p. 13; VII.A.1.c.ii.C–F (including the Medicare note), c.iii.B.1 (Schedule C) and c.v p. 14; VII.B.1.a p. 31; VII.B.1.c p. 32; VII.B.3.a.ii.B p. 33; VII.B.3.b.iii pp. 34–35; VII.B.4.b p. 35; Appendix A p. 39; Appendix B Sections 1–2 p. 40 and Sections 3–4 p. 41. Where they appear. Each parameter title, variable # PDF pages comment and test header now uses these pages. Revision 13 references. fpg_year_lag, az_liheap_income_limit and the test headers cite the 2025-10-30 capture, p. 37 for the FY2026 table. child_unearned_income_counted and the unearned variable cite the capture's p. 9 for the revision 13 sentence. The Wayback service returned HTTP 429 today, but round 1 read that same capture and confirmed both pages. Reference format. Multi-page titles are quoted and end #page a,b-c, with the href on the first page.
S4: rulespec-us#1833 described an older head	Fixed	The issue was updated 2026-10-24 00:46 UTC. It names head 406a5efe6a and commits 49fa4c2f47 and the merge. Required outputs. The unearned list holds the head's 19 sources: total_unemployment_compensation, military_retirement_income, farm_rent_income, gambling_winnings and gross social_security, each floored at zero. Countable income is defined as max(E + U + tanf − the members' Part B premiums, 0). Tests. It counts 124 cases. Companion test 8(a) is now $320, rows 12(m)–(o) cover military retirement, the SBP annuity, farm rent and gambling, and row 15 covers the Medicare premium and the rental loss. Interpretations. 7 (tanf) and 9 (the household subtraction) are revised. Details are under Axiom line assessment.
S5: the zero-cost burden guard was unpinned	Fixed	T/points/az_liheap_energy_burden_points.yaml Case 18 (line 407) has no income, heat in rent and no bills. The cost is 0, so V/points/az_liheap_energy_burden_points.py:40 gives 0 burden points. Income 0 / 33,684 gives 5 income points, for 5 points and $320. Without line 40, the division's out=inf would score 6, for 11 points and $480, so the case would fail.
G1: count TANF through the take-up-gated tanf	Fixed	P/eligibility/categorical_programs.yaml:10-11 lists snap and tanf, and countable income adds tanf. On main, tanf has defined_for = "takes_up_tanf_if_eligible" and adds tanf_if_takes_up, whose state list includes az_tanf. The seven az_tanf: 0 pins are now tanf: 0, and integration Case 4 inputs tanf: 4_164. The remaining az_tanf test inputs still feed tanf; countable income Case 1 ($13,164) exercises that path.
G2: a heat-in-rent household with UNSPECIFIED fuel	Declined, accepted	heating_type is a required input, and callers send the fuel. Axiom interpretation 13 and #9754 record it. This is the same decision I accepted on #10303.
G3: use hud_utility_allowance for the subsidized-housing test	Declined, accepted	It returns 0 for Arizona counties, so microsimulation would not change. The body lists the test as not modeled, and Axiom interpretation 16 records the "greater than or equal to" versus "exceeds" difference.
G4: gambling and farm rent	Fixed	P/income/sources/unearned.yaml:34 adds farm_rent_income and line 42 adds gambling_winnings, both floored per source. Countable unearned Case 13: 4,800 + 1,200 = 6,000, and with wages 22,000 + 6,000 = 28,000. The comment records that plan 1.9 leaves one-time lottery winnings unchecked and that the input cannot separate them. See G8(b) for a refinement.
G5: FY2027 is published, and the July 1 switch was undocumented	Fixed	Statements. The body's "Years covered" table and integration Case 6 now say that revision 16A prints the FY2027 limits and the model reproduces them, with 2027 reproduced but not claimed. References. fpg_year_lag cites both Appendix A tables. Timing. The body explains that model year 2026 uses the FY2026 limits all year, although revision 16A took effect July 1, 2026. verified_years: "2026" is kept, as round 1 allowed. The optional 2027 grid case was not added.
G6: small test and polish items	Partly taken; the rest declined (optional)	"(contract R1)" is gone. The mixed-state case and the registry order are declined. The state-gated keys are still safe: az_liheap_household_size feeds only clip(), smi_size_factor() arithmetic and where(), and the Microsimulation job passed.

New findings

Critical (must fix)

None.

Should address

None.

Suggestions

G7. The Medicare note is not limited to Part B, and medicare_part_a_premium exists.

• The rule. Policy VII.A.1.c.ii.D (p. 14): "Note: Expenses related to Medicare (such as premiums) should be subtracted when determining gross income."
• The input. main (and this PR's base) has medicare_part_a_premium: person-level, annual, "paid out of pocket by the enrollee, net of Medicare Savings Program coverage". In 2026 it is $311 a month with 30–39 quarters of coverage, $565 with fewer than 30, and $0 at the default of 40 quarters.
• What the PR says. The code documentation says "Part D has no premium variable". The body says "Medicare expenses other than the Part B premium, such as Part D premiums, have no input", which is not true of Part A.
• Example (hand trace, 2026). A single person aged 67 has $36,500 of Social Security, 35 quarters of coverage, electric heat and a $1,800 bill. At $3,042 a month, the Medicare Savings Program pays neither premium.
  • Head: 36,500 − 2,434.80 = 34,065.20 > 33,684, so $0.
  • With Part A: subtracting another 12 × 311 = 3,732 gives 30,333.20. That is 90.05% (1 point), a 5.93% burden (1 point) and the elderly point: 3 points and $160.
• Why only a suggestion. About 99% of enrollees get premium-free Part A (the variable's own documentation), and no merged LIHEAP state deducts Part A. It is the same severity as Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 G7.
• Fix: add "medicare_part_a_premium" to the add() list at line 58 with a case. Otherwise, correct the body and documentation to list Part A as not subtracted. If the code changes, update Axiom interpretation 9 and the countable-income output.

G8. Two optional refinements.

• (a) The household floor has no test. No case has premiums above gross income, so removing max_(…, 0) at line 59 would fail no test. The effect would be limited to the reported az_liheap_countable_income. A negative ratio still scores 5 income points (the scale's first threshold is -inf), and the burden division already treats income ≤ 0 as unbounded, so eligibility and the benefit would not change. If wanted, add a case with $1,200 of interest and a pinned $2,434.80 premium, expecting countable income 0.
• (b) "Gambling profits". VI.A.6.e.ii.B (p. 9) counts "gambling profits", and main has a gambling_losses input beside gambling_winnings. Counting max(gambling_winnings − gambling_losses, 0) per person would follow the word "profits". Round 1 named gambling_winnings, so recording the gross-winnings choice in the comment would also be fine.

Verified

The merge resolution (004ed274b4, programs.yaml).

• The resolved coverage line is AR, AL, DC, GA, Riverside County, MA, FL, IL, AZ, IN, KS, KY, MD, MS, NC, NE, NJ, NY, OH, OK, OR, SD, RI, TX. That is main's line (which gained AR and GA) plus AZ, with nothing dropped or duplicated.
• The state_implementations list holds the AZ LIHEAP entry once.
• Against main, the PR's only programs.yaml changes are AZ on the coverage line and the AZ entry after IL.
• test_programs_registry passed in CI.
• The merge also brought main's two Arizona charitable-deduction files, which are identical to main. git diff 004ed274b4 406a5efe6a touches only the 8 Arizona LIHEAP files of the last commit.

Hand-checks of every new or changed expectation. All use 2026, the size-1 limit of $33,684 (12 × $2,807) and the premium 12 × $202.90 = $2,434.80.

New cases:

• Countable income Case 3 (age 67, Social Security $34,000, premium $2,434.80, electric $1,800). Unearned 34,000. Countable 34,000 − 2,434.80 = 31,565.20 ≤ 33,684, so income eligible. Income 0.9371 gives 1 point, burden 0.0570 gives 1 point, and elderly gives 1: 3 points, $160.
• Countable income Case 4 (age 67, pension $24,000, premium $2,434.80). Unearned 24,000, countable 21,565.20. At $2,000 a month the person is above the QI limit, so the pinned premium is the computed one.
• Countable unearned Case 12 (wages $36,000, rental −$6,000). Unearned 0, countable 36,000 > 33,684. The household is not income eligible and not eligible (no SNAP or TANF), so $0.
• Countable unearned Case 13 (wages $22,000, farm rent $4,800, gambling $1,200). Unearned 4,800 + 1,200 = 6,000, countable 28,000. At age 58 there is no Medicare premium.
• Energy burden Case 18. Countable income 0 and cost 0, so 0 burden points (the guard). 5 income points give 5 points and $320. Heat in rent with NATURAL_GAS makes the household eligible.

Changed expectations:

• Integration Case 2 (age 70, Social Security $36,000, premium $2,434.80, SNAP $2,400, propane; electric 1,200 + bottled gas 1,500).
  • Income. Countable 33,565.20 ≤ 33,684, so income eligible; it is also categorically eligible. Cost 2,700.
  • Points. Income 0.9965 gives 1. Burden 0.0804 gives 1, plus 2 for propane: 3. Elderly gives 1. Total 5, so $320.
• Countable unearned Case 7 (railroad $30,000, premium $2,434.80). Unearned 30,000, countable 27,565.20.
• az_liheap.yaml Case 14 (railroad $40,000, premium $2,434.80, no SNAP or TANF). Countable 37,565.20 > 33,684. The household is not income eligible, not categorically eligible and not eligible, so $0.
• Countable unearned Case 1 (Social Security $23,712, pension $6,000, premium input). The expectation returns to round 1's 29,712, since the premium no longer comes off at the person level.

Pin-only and rename-only edits:

• Premium pins. Income-eligible Cases 6–9 pin the premium of the non-earning members aged 66, 68 and 70 at 0, and countable income Case 2 pins its 67-year-old at 0. Their boundary totals (97,716 / 97,717 and 122,460 / 122,461) and 46,400 are unchanged and still correct.
• tanf renames. Five income-eligible cases, one household-size case, one earned-income case and integration Case 4 now use tanf. Their expectations are unchanged. Integration Case 4 gives 4,164 / 44,052 = 9.5% (5 points), 0 burden points and the child point: 6 points, $320.
• Other elderly cases. az_liheap.yaml Case 8 (age 66, VA $8,400) scores 17 points either way: even with a full premium, the income and burden bands stay at 5 and 6 + 2. The energy-need cases output only need points.

Case count. 14 + 7 + 5 + 10 + 11 + 3 + 6 + 4 + 13 + 6 + 18 + 15 + 12 = 124, as the body says. CI's per-file results match file by file.

New-code checks:

• No cycle. medicare_part_b_premium reads the gross premium and MSP coverage, neither of which reads LIHEAP. tanf reads no LIHEAP variable.
• Mutations:
  • Removing the premium subtraction fails countable income Cases 3–4, unearned Case 7, integration Case 2 and az_liheap.yaml Case 14.
  • Removing the per-source unearned floor fails unearned Case 12.
  • The take-up gate itself lives in main's tanf. As in the merged states, the household tests run with take-up on; the gate matters in microsimulation, which is the point of G1.
  • The household floor is G8(a).
• Documentation. V/income/az_liheap_countable_income.py:9-18, the unearned variable's documentation, the list comments and the body match the code. The one exception is the Part A wording (G7).
• Descriptions. All 16 parameter descriptions still end "under the Low Income Home Energy Assistance Program."; none changed.
• Changelog. changelog.d/az-liheap-wave1c.added.md is unchanged and still correct.

Checklist results (LIHEAP batch):

1. State plan and manual: pass. The published FY2026 cells are unchanged from round 1, and the FY2027 table is reproduced and documented (G5).
2. Income definition: pass. The Part B premium is subtracted (S1), every source is floored (S2), wages count gross, and farm rent and gambling count. Part A is G7.
3. Backdating: pass for 2026. Earlier years are documented backfill, and FY2027 is reproduced but not claimed.
4. Household and arrangement rules: pass. The rules are unchanged, the zero-cost guard is pinned (S5), and G2 and G3 are declined with reasons.
5. Tests: 124 cases, all periods plain. Every new or changed expectation checks by hand.
6. Descriptions: pass.
7. References: pass. The revision 16A anchors show their provisions (S3), the revision 13 values cite the Wayback capture, and multi-page titles use the quoted #page form.
8. Wiring: pass. The registry and resolved coverage line are correct, gating is unchanged, take-up now flows through tanf (G1), and there is no aggregate wiring, as in every merged LIHEAP state.
9. Axiom: valid (Updated Oregon tax parameters for 2022 #1833, now current).
10. Branch and CI: a clean merge with main and 29/29 green.
11. Integrate modeled state unemployment insurance into income flows #9558: pass. The list reads total_unemployment_compensation, and the guard passes.
12. IIJA / FY2027: not applicable. There is no separate supplement, and FY2027 is reproduced but not claimed.
13. Mutation check: every policy branch is pinned. The only exception is the household floor, which cannot change a benefit (G8(a)).
14. Document disjoint health premium inputs and correct consumer treatment #10046: not applicable. Wages come from gross employment_income, and the only premium deducted is Medicare.
15. State-gated index defaults: safe and unchanged.
16. Wire military retirement pay and survivors into federal and state tax (#10181) #10182 / Count military SBP annuities in state benefit income lists #10317: pass. The list reads military_retirement_income, and the Count military SBP annuities in state benefit income lists #10317 guard passes.
17. Merged state SSPs: not applicable; main has no Arizona state supplement variable.

Federal 110% floor: never binds. The limits are unchanged from round 1, at about 1.36 times the floor.

Axiom line assessment

Valid: axiom: TheAxiomFoundation/rulespec-us#1833 queued.

• State: OPEN, labelled enhancement and pe-parity, created 2026-10-20 and updated 2026-10-24 00:46 UTC.
• It matches the head:
  • It names head 406a5efe6a and the commits since c12ed6dbd4.
  • It lists 16 parameters (sources/unearned with 19 entries; categorical_programs with snap and tanf), the 14 variables and 124 cases by file.
  • Its required output for countable income is max(earned + unearned + tanf − the members' medicare_part_b_premium, 0), with every source floored. That is the head's formula.
• It is dispatch-ready in the rulespec-us#1467 format:
  • module paths with corpus status;
  • verbatim text of revisions 13, 15 and 16A, including a revision 16A page map that matches the pages I checked;
  • plan items 1.1–2.6, both Appendix A tables, the SMI tables and both guideline notices;
  • 15 companion-test rows derived from the sources;
  • 17 interpretations;
  • its blockers: sources missing from the corpus, bundle scope, an unchecked signed release, billed-run approval, and no reviewed oracle revision.
• Note. If G7 is adopted, update interpretation 9 ("Part D and other Medicare expenses have no input") and the countable-income output.

CI status

29 pass, 0 pending, 0 failed. Run 40046280214 ran on head 406a5efe6a (pull_request, created 2026-10-24 00:42 UTC, after #10287 and the 2026-10-21 cutoff). I re-checked gh pr checks 10293 at the end of this review.

• Arizona LIHEAP tests. States-shard-4, batch 1/13 (states/az), ran all 13 files: 14 + 7 + 5 + 10 + 11 + 3 + 6 + 4 + 13 + 6 + 18 + 15 + 12 = 124 passed.
• Guards (Rest shard-1):
  • the four test_unemployment_compensation_readers.py tests (Integrate modeled state unemployment insurance into income flows #9558);
  • the four test_military_retirement_readers.py tests (Count military SBP annuities in state benefit income lists #10317);
  • the test_source_conflicts.py structural tests, including test_conflict_sounding_comments_do_not_grow;
  • test_members_are_state_gated;
  • test_programs_registry.
• Also passing: Microsimulation, Household API Partners, PR validation, Package and compatibility, Quick Feedback, Codecov, and every baseline and contrib shard.
• Known main-caused failure: not applicable.
• Locally: I ran no tests or model probes. The new expectations, G7 and the mutation claims are hand traces of the code at the head.

Branch status

• Position: 13 commits ahead of main (0e7ced1747) and 34 behind. The merge base is 6a92d6a983.
• Merge: clean. git merge-tree --write-tree PolicyEngine/main 406a5efe6a exits 0.
• Main's 34 newer commits touch no Arizona LIHEAP dependency: Medicare, MSP, TANF, SNAP, SSI, SMI, guidelines, the income inputs or programs.yaml.
• The ratchet on the merged tree. In test_source_conflicts.py, main changed only KNOWN_UNMARKED entries for California and federal files, and CONFLICT_COMMENT_RE is unchanged. Under that pattern, the 30 Arizona LIHEAP parameter and variable files have 0 matching lines, so the ratchet holds on the merged tree.
• Sibling conflicts (branch note). A trial merge with each open LIHEAP PR conflicts only in policyengine_us/programs.yaml. The PRs are Add Pennsylvania LIHEAP regular heating assistance #9971 (PA), Add Iowa LIHEAP regular heating assistance #10292 (IA), Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 (VA), Add Alaska LIHEAP regular heating assistance #10341 (AK), Add North Dakota LIHEAP regular heating assistance #10342 (ND), Add New Hampshire LIHEAP regular heating assistance #10343 (NH), Add Utah LIHEAP regular heating assistance #10344 (UT), Add Washington LIHEAP regular heating assistance #10345 (WA), Add Wyoming LIHEAP regular heating assistance #10346 (WY), Add Louisiana LIHEAP regular heating assistance #10429 (LA), Add Tennessee LIHEAP regular energy assistance #10430 (TN), Add New Mexico LIHEAP regular heating assistance #10431 (NM), Add Montana LIHEAP regular heating assistance #10435 (MT) and Add Missouri LIHEAP Energy Assistance #10438 (MO). Count military retirement in KS, MS, NC, NJ and NY LIHEAP income #10409 merges cleanly. Whichever lands first, the rest need a one-line resolution.

0 critical, 0 should and 2 suggestions are open at this head.

Verdict: APPROVE

[DTrim99]

Round 2: all five should items are fixed. Part B premiums now come off gross income ($34k SS now gets $160), unearned sources are floored per person, the policy anchors are correct, rulespec-us#1833 matches the head, and the zero-cost guard is pinned. The hand-resolved programs.yaml merge is correct, and all 124 AZ cases pass. Two optional suggestions, including Part A premiums (same as VA G7). Full report in the comment above.

[hua7450]

Thanks, David. e1fd459 takes G7 and G8(b):

• G7: az_liheap_countable_income now subtracts medicare_part_a_premium together with medicare_part_b_premium. The Part A premium is 0 for premium-free Part A, the default, so no existing case changes.
• G8(b): gambling now counts as profits: each member's gambling_winnings less gambling_losses, floored at zero, following "gambling profits" in VI.A.6.e.ii.B (page 9).
• G8(a): the floor test is not added. As you note, it changes no eligibility or benefit.

All 124 cases pass locally. The commit also moves the registry entry next to AR and stops this PR from editing the LIHEAP coverage line. #10303 now adds IA, AZ and VA there, so the three PRs merge without conflicts, with #10303 last. TheAxiomFoundation/rulespec-us#1833 is updated to this head.

[DTrim99]

PR Review (round 3): Add Arizona LIHEAP Standard benefit

Summary

Head e1fd45905e, one commit after our round-2 approval (406a5efe6a). It applies our round-2 suggestions G7 (Part A premiums) and G8 (gambling profits), and it removes AZ from the shared coverage line, which #10303 now edits.

The changes

• Part A premiums: correct. az_liheap_countable_income subtracts medicare_part_a_premium + medicare_part_b_premium. Policy VII.A.1.c.ii.D's note and plan 1.9 ("Excluding MediCare deduction") cover Medicare premiums generally. On main, medicare_part_a_premium is out-of-pocket, net of MSP, and enrollee-only.
• Gambling profits: correct. gambling_winnings is removed from sources/unearned.yaml, and the formula adds max_(gambling_winnings - gambling_losses, 0) per person. That follows Section VI.A.6.e.ii.B ("gambling profits", p. 9), with no double count and losses not offsetting other income.
• Coverage line and programs.yaml: AZ is removed from the coverage line (Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 adds it), and the AZ state_implementations entry is moved, with its content unchanged.

New finding

Should 1: both new branches are unpinned. No test has a Part A premium or gambling losses, so removing either would pass every case. Per the LIHEAP batch mutation rule, unpinned new logic is should-address. Add two cases:

• a Medicare enrollee with a Part A premium;
• gambling winnings with partly offsetting losses (e.g. $3,000 winnings and $1,000 losses counts $2,000), plus losses above winnings, which floors at $0 and doesn't reduce wages.

CI and branch

At review time, 6 checks passed and 16 were pending; let CI finish green, including the registry test. Merge before #10303, which re-adds AZ to the coverage line.

Verdict: REQUEST_CHANGES

[DTrim99]

Round 3: the Part A premium subtraction and the gambling profits (winnings less losses, floored per person, no double count) are both correct. One should-address item: neither new branch has a test, so add a Part A premium case and a gambling-loss pair. Let CI finish and merge before #10303. Full note in the comment above.

[hua7450]

Thanks, David. e010083 adds the three cases:

• Part A premium: countable income Case 5. A 67-year-old with a $24,000 pension pays the 2026 reduced Part A premium (311 x 12 = 3,732) and the 2,434.80 Part B premium: 24,000 - 3,732 - 2,434.80 = 17,833.20.
• Partly offsetting losses: countable unearned Case 14. $3,000 of winnings less $1,000 of losses counts $2,000.
• Losses above winnings: countable income Case 6. $1,000 of winnings and $3,000 of losses count $0, and $20,000 of wages stay $20,000.

Each case fails if its branch is removed. All 127 cases pass locally. TheAxiomFoundation/rulespec-us#1833 and the body are updated to this head.