[hua7450]

Adds Maine HEAP Fuel Assistance, the state's LIHEAP regular heating benefit administered by the Maine State Housing Authority (MaineHousing) under 99-346 CMR ch. 24, for the 2025-26 and 2026-27 heating seasons (model years 2026 and 2027). The model counts citizens, nationals and qualified aliens in household size (all members' income still counts), tests income against the greater of 150% of the poverty guideline and 60% of state median income (or SNAP or TANF receipt), requires a heating bill or heat included in the rent, and scores points for dwelling type, county, fuel, at-risk members and subsidized housing. It adjusts the points by the household's poverty-level multiplier, prorates them for ineligible members, rounds up and multiplies by the dollar value per point. Subsidized tenants with heat included in rent receive $21.

Fixes #10427

The two seasons use different rule editions: the 2025 edition (SOS filing 2025-135, the same matrix as the 2024 edition) for 2025-26, and the replacement rule effective June 29, 2026 (SOS filing 2026-134) for 2026-27, which adds 8 base points and changes every points table and the multipliers.

The dollar value per point is an estimate. MaineHousing announces it after each federal award and has published none for FFY2025-FFY2027. $22 is inferred from the FFY2025 and FFY2026 plans' $1,012 maximum (the 2025-edition maximum of 35 points x 130% = 45.5, rounded up to 46, x $22), which also fits their $88 minimum (4 x $22). The draft FFY2027 plan in MaineHousing's April 2026 board packet (section 2.6) repeats $88 and $1,012 beside a reviewer note to obtain the figures, so it supplies no new value; at $22 the June 29, 2026 matrix pays from $154 (10 points x 0.7 = 7) to $1,188 (30 points x 1.8 = 54). MaineHousing's October 2026 board packet expects the FFY2027 Notice of Award by the end of October, and rule 4(A) promises the value within 15 days of the award. The model reuses $22 for 2026-27 until MaineHousing announces a value.

Regulatory authority

• 99-346 CMR ch. 24, Home Energy Assistance Program Rule, effective June 29, 2026, sections 1, 3, 4, pages 2-17
• 99-346 CMR ch. 24, 2025 edition (SOS filing 2025-135), its points matrix in the FY2026 Benefit Matrix, pages 1-2, and MaineHousing's PDF of that edition as archived July 22, 2025, section 4(A)
• FY2026 LIHEAP Detailed Model Plan, sections 1.4, 1.7, 1.9, 2.1, 2.6, pages 5-10 and FY2025 plan, section 2.6
• MaineHousing April 2026 board packet, draft FFY2027 plan section 2.6
• MaineHousing HEAP page income limits: 2026-2027 (archived October 15, 2026) and 2025-2026 (archived November 1, 2025)
• 42 U.S.C. 8624(b)(2)(B)

Eligibility

Requirement	Source	How modeled
Maine residence	Rule 3(A)(4)	defined_for = StateCode.ME
Citizens, nationals and qualified aliens	Rule 3(A)(1)	me_heap_household_size sums is_citizen_or_legal_immigrant; size 0 is ineligible
Income at most the greater of 150% FPG and 60% SMI	Rule 3(C); 2025 edition 4(A); Plan 2.1; MaineHousing charts	me_heap_income_limit, prior-year guideline; reproduces the 2025-26 chart for sizes 1-10 and the 2026-27 chart. For 10 people in FFY2026 the rule's 70% row and the chart give $102,008 (60% SMI), while plan 2.1 assigns 150% FPG ($97,725); the model follows the rule and the chart (candidate us-me:liheap-size-ten-income-limit)
Categorical income eligibility (TANF or SNAP)	Rule 3(C)(2); Plan 1.4	SNAP or TANF receipt passes the income test. The multiplier uses actual countable income, which 3(C)(2) permits ("using actual vetted income"); plan 1.4a's "highest FPL allowable" percentages would come from MaineHousing's HEAP Guide, which is no longer available
Energy cost for heat and a heating system	Rule 1(M), 1(HH), 3(A)(4), 3(B)(1)(a), 4(A)	A Direct Energy Cost (a heating bill the household pays, has_heating_expense) or an Indirect Determinable Energy Cost (heat included in rent, heat_expense_included_in_rent); a household with no bill and heat outside the rent is ineligible. OTHER (wood pellets, corn, bio-fuel, biobricks) qualifies with its bill, and rule 5(A)(5) pays households heating with these fuels by direct check. SOLAR uses the electricity row (grid-tied home with electric heat), and an off-grid solar-only home has no electricity bill, so it has no energy cost and is ineligible. NONE fails the functioning-heating-system test. UNSPECIFIED is ineligible unless subsidized with heat in rent (#9754)

Countable income

Item	Source	How modeled
Members counted	Rule 3(C)(1)	Members 18 and older ("over the age of 18"), of every immigration status; plan 1.9 leaves "Earned income of a child under the age of 18" unchecked, consistent with counting 18-year-olds
Earned income	Rule 3(C)(1)(a)-(b)	Wages and net self-employment, including partnership and S corporation income, each floored at zero; a full-time high-school student's earnings are excluded unless the student is the applicant (tax-unit head)
Unearned income	Rule 1(EE), 3(C)(1)(c)-(n)	Social Security and SSI including Medicare deductions, Maine's SSI supplement (me_ssp), unemployment, workers' compensation, strike benefits, alimony, child support, VA benefits, cash gifts (financial_assistance), pensions and annuities, military retirement, Railroad Retirement and non-Social Security survivor annuities (3(C)(1)(i) "regular annuity payments"), long-term disability, Maine paid family and medical leave benefits (pfml_benefits, payable from May 1, 2026), interest, dividends, estate and trust income, rental income, and the household's TANF grant, counted once from the take-up-gated tanf
Not counted	Rule 3(C)(1) exclusions	General Assistance (non-cash voucher income, exclusion (j); no input), retirement-account and other asset drawdowns (exclusion (a)), tax refunds, lump sums, SNAP
TANF and long-term disability	Rule 1(EE), 3(C)(1); Plan 1.9	The rule counts income "from all sources" unless excluded, and no exclusion names TANF or recurring insurance payments. Plan 1.9 leaves TANF and "Insurance payments made directly to the insured" unchecked. The model follows the rule for both (candidate us-me:liheap-tanf-and-disability-income): a TANF family of three heating with oil in Penobscot counts $13,140 and receives $704, against $748 with TANF excluded
Medical-expense adjustment	Rule 3(C)(1), last paragraph	An over-income household deducts medical expenses (premiums and other medical costs) only up to the amount needed to reach the limit

Benefit

Points	2025 edition (2025-26)	Replacement rule (2026-27)
Base	0	8
Dwelling: stick-built or modular / mobile or manufactured / condo, duplex or apartment	9 / 8 / 6	3 / 2 / 1
County	2 (Kennebec, Sagadahoc, Washington) to 7 (Aroostook)	1 (Cumberland, Kennebec) to 6 (Aroostook)
Fuel: electricity / propane / kerosene / oil / coal / natural gas / wood / OTHER (inferred)	14 / 10 / 8 / 7 / 5 / 5 / 4 / 5	8 / 5 / 5 / 4 / 4 / 3 / 3 / 3
Member 60+, disabled or 6 and under / else child 7-17	5 / 3	5 / none
Subsidized household paying for heat	-9	-3
Poverty-level multiplier	130% (0-25%) to 70% (above 150%), whole-percent rounding	1.8 (0-10.99%) to 0.7 (176% and above), two-decimal rounding

• OTHER stands for wood pellets, corn, bio-fuel and biobricks, which have no heating_type value, so its points are an inferred mapping: the lowest row of those fuels. That is 5 in the 2025 edition (wood pellets 5, corn 5, bio-fuel including bio-bricks 6) and 3 under the June 29, 2026 rule (wood pellet 4, biobrick 3). The 2026 rule has no corn row, although rule 5(A)(5) and MaineHousing's HEAP page still list corn, so a corn household gets the biobrick row's 3. Every other OTHER household scores at or below its own fuel's row: a pellet household gets 3 against its row's 4 in 2026-27, and a bio-fuel household gets 5 against 6 in 2025-26.
• Points x multiplier x eligible share of members, rounded up, x $22 (estimate). Subsidized tenants with heat in rent, including public housing tenants: $21 (rule 4(B); plan 1.7).
• At-risk points go to the first qualifying member only. The April 2026 proposed-rule memo said the new matrix "will add points for additional at-risk household members", but the adopted table prints "Points for the first in the house".
• New input me_heap_dwelling_type, defaulting to stick-built or modular, the all-state LIHEAP dwelling default.

Not modeled

Item	Source	Treatment
TANF Fuel Supplemental Benefit ($300 per the PY2025 notice; removed by the 2026 rule)	2025 edition 3(A), 4(B)	TANF-funded supplement, excluded
Separate wood pellet, corn, bio-fuel and bio-brick rows	Rule 4(A)	No heating_type value; these households report OTHER, which is eligible with its bill and takes the lowest of those rows (see Benefit). WOOD uses the cordwood row
Roomers as separate households, live-in attendants, optional exclusion of college students	Rule 3(A)	No inputs
Residency and dwelling-unit tests, HEAP Guide procedures	Rule 3(A)-(B)	Not represented. MaineHousing posted the PY2026 HEAP Guide (effective 8/29/2025) in its partner library; the file now returns 404 and has no Wayback capture
ECIP crisis, weatherization, CHIP, heat pumps	Ch. 24 (other components)	Out of scope

Shared parameter

The income limit reads gov.hhs.liheap.fpg_limit (150%, 42 U.S.C. 8624(b)(2)(B)(i)), which main gained with #10342 (North Dakota LIHEAP). This branch takes main's file and adds no federal parameter.

Source conflict candidates

Two source_conflicts/candidates.yaml entries record where the model follows the rule over the FY2026 plan (follows: statute, state: ruled), each listing the files that implement its reading:

• us-me:liheap-size-ten-income-limit (FFY2026): the 2025 edition's 4(A) 70% row and the chart ($102,008) against plan 2.1 (150% FPG, $97,725). Code: eligibility/me_heap_income_limit.py.
• us-me:liheap-tanf-and-disability-income (FFY2026-2027): rule 1(EE) and 3(C)(1) against plan 1.9's unchecked TANF and insurance boxes. Code: income/sources/unearned.yaml and me_heap_income.py.

Review round 1

Commit 7d4e456 addresses DTrim99's round 1 review; cc78d48 merged main at c55b806.

• Counted: Railroad Retirement and non-Social Security survivor annuities, Maine SSP, Maine paid family and medical leave benefits, and TANF (rule over plan 1.9). Long-term disability stays counted under the same rule.
• OTHER with a bill became eligible; the eligibility test no longer requires a fuel listed in the points matrix.
• New tests pin every earned and unearned source, other_medical_expenses, the public housing branch of the $21 benefit and an OTHER homeowner.
• The 2026-27 income chart reference moved from the overwritten /charts/ page to the October 15, 2026 capture of the HEAP page.

Declined:

• Paying unsubsidized heat-in-rent tenants with an UNSPECIFIED fuel. heating_type is a required input, and UNSPECIFIED pays $0 except for subsidized heat in rent; Default heating_type to electricity and remove the UNSPECIFIED-gated state heating adapters #9754 tracks the default.
• Deriving the dwelling-type default from tenure. The all-state LIHEAP convention defaults the dwelling type to a single-family house, which is stick-built or modular here.
• Replacing the 23 references to the Secretary of State's Word copy of the 2025 edition with the July 22, 2025 capture of MaineHousing's rule PDF. The Word copy and the 2026 rule PDF have no Wayback capture, and this round adds captures only of the exact document cited.
• Changing the $22 value per point for 2026-27. No newer figure is published.

Review round 2

Commit 64e3aeb addresses DTrim99's round 2 review; the head, 143d9b8, merges main at a24c9cb, keeping AK, NM and ME on the LIHEAP coverage line and the Maine candidates in id order.

• OTHER takes the lowest row of the fuels it stands for (see Benefit). At 0 fuel points, a voucher tenant in a Kennebec apartment who paid their own pellet bill scored 6 + 2 + 0 - 9 = -1 point and received -$22 under the 2025 edition. New me_heap.yaml Case 7 pays that tenant $110: wages of $11,427 are 73% of the guideline (multiplier 1.1), and 6 + 2 + 5 - 9 = 4; 4 x 1.1 = 4.4, rounded up to 5 points.
• me_heap.yaml Case 6, an OTHER homeowner, goes from $176 to $264 (9 + 2 + 5 = 16; 16 x 0.7 = 11.2, rounded up to 12). payment/me_heap_points.yaml Cases 3 and 4 add an OTHER household: 16 points in 2026 and 15 in 2027.
• The model adds no zero floor. With OTHER scored, an eligible household that pays for heat has at least 1 raw point under the 2025 edition (apartment 6 + unlisted county 0 + wood 4 - 9) and 9 under the 2026 rule. The multiplier is at least 0.7 and the eligible share is above zero, so every points-based benefit rounds up to at least one point ($22).
• Both candidates list their code files in place of code: [].
• The value_per_point.yaml comment gives the 2026-27 minimum as $154.

Declined:

• Dated Wayback captures of the June 29, 2026 rule PDF and the Secretary of State's Word copy. The rule PDF's July 22, 2025 capture holds the 2025 edition, and the Word copy has no capture; the wave cites existing captures of the exact edition and does not create new ones.

Test plan

49 YAML cases in 9 files: me_heap.yaml 7, me_heap_household_size.yaml 1, me_heap_income.yaml 12, integration.yaml 4, eligibility/me_heap_categorically_eligible.yaml 2, eligibility/me_heap_eligible.yaml 4, eligibility/me_heap_income_limit.yaml 3, payment/me_heap_income_multiplier.yaml 4, payment/me_heap_points.yaml 12. They cover the income limit against both published charts and a size where 150% FPG exceeds 60% SMI; counted members, every earned and unearned source with a distinct amount, TANF, the per-source floor, the high-school student rule and both sides of the medical-expense adjustment (premiums and other medical expenses); categorical SNAP and TANF receipt; fuel and housing eligibility, including OTHER with a pellet bill; the multiplier band edges and rounding in both editions; every dwelling type and fuel, including OTHER's inferred row in both editions, high, low and unlisted counties, priority points, the subsidized adjustment (including a voucher tenant paying for pellets, $110), base points, proration and the round-up guard; the plan maximum ($1,012), the $21 benefit for voucher and public housing tenants, and four end-to-end households, one of which heats with oil, has no bill and no heat in the rent, and is ineligible. Each paying case with heat outside the rent carries a heating bill for its fuel, taken from EIA's October 2026 Short-Term Energy Outlook winter fuels table and the Maine Department of Energy Resources price survey of January 5, 2026 (cordwood and pellets); the coal entry uses the heating-oil amount because neither source publishes a residential coal price. Expected values are hand-computed from the rule tables. CI passed at cc78d48 (35 of 35 checks, covering the 48 cases then in the folder). The round 2 cases (me_heap.yaml Case 6 re-pinned to $264, Case 7, and the OTHER household in payment/me_heap_points.yaml Cases 3 and 4) were hand-derived and not run locally, and CI has not yet run at 143d9b8.

• YAML tests with hand-computed expected values
• CI passes
• Changelog fragment in changelog.d/

axiom: TheAxiomFoundation/rulespec-us#1898 queued

🤖 Generated with Claude Code

[DTrim99]

PR Review: Add Maine HEAP Fuel Assistance

PR #10437 (author: hua7450), head bbdb9b5f78. This is a first review. The PR adds HEAP Fuel Assistance, Maine's LIHEAP regular heating benefit administered by MaineHousing under 99-346 CMR ch. 24, for the 2025-26 and 2026-27 seasons (model years 2026 and 2027). It includes:

• 20 parameters (19 Maine files plus the shared gov.hhs.liheap.fpg_limit) and 9 variables (8 computed, plus the new input me_heap_dwelling_type);
• 9 test files (43 cases);
• a programs.yaml entry (coverage line and state list);
• a changelog fragment.

The PR has no comments or reviews yet, and it touches no partner test file.

Path prefixes:

• P/ = policyengine_us/parameters/gov/states/me/msha/heap/
• V/ = policyengine_us/variables/gov/states/me/msha/heap/
• T/ = policyengine_us/tests/policy/baseline/gov/states/me/msha/heap/

Sources read for this review:

• Rule, June 29, 2026 replacement (SOS filing 2026-134): 99-346 CMR ch. 24, file pages 1-4 (definitions), 6, 10-17 (eligibility, income, benefit matrix, payment) and 33 (effective date).
• Rule, 2025 edition (SOS filing 2025-135): the Secretary of State's Word copy, definitions, sections 3-5 and the filing history, plus its matrix in the FY2026 Benefit Matrix, pages 1-2.
• State plans: the FY2026 Detailed Model Plan, pages 4-10 (I rendered pages 5-7 to read the boxes), and the FY2025 plan, page 8 (rendered; the file is a scan). No FY2027 plan is on the Clearinghouse.
• MaineHousing:
  • the HEAP page captured 2025-11-01 (2025-26 chart and the accepted fuel types) and the 2026-27 chart (page modified 2026-07-22);
  • the April 28, 2026 board packet: the proposed-rule memo (file page 66), the proposed matrix (page 84) and the draft FFY2027 plan (page 110, rendered);
  • the August 18, 2026 board packet: the adoption minutes (page 5) and the Energy and Housing Services report (page 67);
  • the HEAP Announcement public notice (2025-26 season).
• Federal: 42 U.S.C. 8624(b)(2)(B) and IRS Publication 502 ("Employer-Sponsored Health Insurance Plan"; "Medicare Part B").
• Not obtainable: MaineHousing's PY2026 HEAP Guide (search indexes list "PY2026 HEAP Guide, Effective 8/29/2025" in its partner library, but the file now returns 404 and has no Wayback capture).

Summary

What is right. The published values and most rules are encoded correctly:

• Points matrices. Every cell matches its edition: the 2025 edition (dwelling 9/8/6, 16 counties from Aroostook 7 to Kennebec, Sagadahoc and Washington 2, fuels 14 to 4, priority 5 or 3, subsidized -9, seven multiplier bands with whole-percent rounding) and the June 29, 2026 rule (base 8, dwelling 3/2/1, 16 counties from Aroostook 6 to Cumberland and Kennebec 1, fuels 8 to 3, at-risk 5 "for the first in the house", heating subsidized -3, eight bands from 1.8 to 0.7). The PR uses the adopted county table, not the April 2026 proposal (which had Franklin 4, Cumberland 2 and Washington 1).
• Income limit. max(150% of the lagged guideline, 60% of state median income) reproduces all 20 published chart rows: 36,836 to 102,008 for 2025-26 and 38,070 to 105,426 for 2026-27.
• Dollar values. $22 a point for 2025-26 is a sound inference: the 2025 edition's largest total, 35 × 1.30 = 45.5, rounds up to 46, and 46 × $22 = $1,012, the FY2025 and FY2026 plans' maximum. The $21 subsidized heat-in-rent amount matches plan 1.7b.
• Countable income. Gross receipts; Social Security and SSI "including Medicare deductions" (rule 3(C)(1)(c) and plan 1.9's checked "Including MediCare deduction" box, so the wave's Medicare-netting precedent does not apply here); a per-source floor on every source, rental and farm rent included; the high-school-student exclusion and its applicant exception; assets drawn down excluded; ineligible members' income counted; and the medical adjustment that stops at the limit.
• Heat in rent. Unsubsidized tenants with heat in the rent score full points (the rule has no reduction), and subsidized tenants receive $21.
• Tests. I hand-checked 24 expectations below, and CI passed all 43 cases.
• Batch checks. The guards all pass: Integrate modeled state unemployment insurance into income flows #9558, Count military SBP annuities in state benefit income lists #10317, the Count each Social Security benefit once in Pennsylvania CCW countable income #10408 pattern and the Tie source-conflict markers to the register shared with Axiom #10287 ratchet (on the merged tree too). Item 17 is a suggestion: me_ssp is on main but not counted.

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

• S1. Railroad and survivor annuities are not counted. Rule 3(C)(1)(i) counts "regular annuity payments", but railroad_benefits and survivor_benefits are missing from the unearned list. A railroad retiree with $20,000 gets $748 instead of $462; with $40,000, $748 instead of $0.
• S2. TANF follows the plan over the rule, while long-term disability follows the rule over the plan. The rule counts "total combined income ... from all sources" unless excluded, and TANF is not excluded. The PR leaves TANF out because plan 1.9 leaves its box unchecked, yet it counts long-term disability in 2025-26 on the rule's "includes, but is not limited to", against the plan's unchecked insurance box. The choice is not recorded. A TANF family of three gets $748 instead of $704.
• S3. Households heating with an unlisted fuel are denied. Eligibility requires a fuel listed in the points matrix, which the rule does not require. The rule pays corn and bio-fuel heaters directly. An OTHER-fuel household with a bill gets $0 instead of $176-$264, and the PR's own test labels that household a pellet stove.
• S4. Untested sources. 3 of the 5 earned sources, 15 of the 17 unearned sources and other_medical_expenses never take a positive value in any test. The public-housing branch of the $21 benefit is also unpinned.

There are also six suggestions:

• G1: unsubsidized heat-in-rent renters with an UNSPECIFIED fuel get $0.
• G2: the 2026-27 dollar value per point is an uncorroborated carry-forward.
• G3: count me_ssp (item 17) and Maine paid family and medical leave benefits.
• G4: record the plan-versus-rule and plan-versus-chart readings in the body and the backlog.
• G5: add Wayback captures for the three overwritten URLs.
• G6: reconsider the stick-built default for me_heap_dwelling_type.

Status.

• CI: 27 pass and 3 skipping. All 43 Maine HEAP cases passed in states-shard-3.
• Branch: 2 commits ahead of main and 41 behind. It merges cleanly.
• Siblings: this PR adds ME to the LIHEAP coverage line, so it conflicts with 17 open LIHEAP siblings in programs.yaml only (branch note).

Critical (must fix)

None.

Should address

S1. Railroad retirement and non-Social Security survivor annuities are not counted, although rule 3(C)(1)(i) counts regular annuity payments

• Where: P/income/sources/unearned.yaml:13-32 lists pension_income and military_retirement_income but neither railroad_benefits nor survivor_benefits. V/me_heap_income.py:28-30 sums only that list.
• Sources:
  • Rule 3(C)(1), both editions (2026 p. 12): "Household Income means the total combined income of all Household Members over the age of 18, unless otherwise excluded from all sources before taxes and deductions ... Household Income includes, but is not limited to, the following: ... i. Government employee pensions, private pensions, and regular annuity payments". Neither exclusion list (pp. 12-15) mentions railroad or survivor annuities.
  • Plan 1.9 (p. 6, rendered) checks "Retirement / pension benefits".
  • On main, railroad_benefits is the Railroad Retirement Board annuity input, and survivor_benefits is documented as "Survivor benefits other than Social Security survivor benefits" (for example, a pension survivor annuity). Neither is part of pension_income, social_security or military_retirement_income, so adding them double counts nothing.
• Effect (hand-traced, 2026; a single retiree aged 70, no medical expenses, oil with a $1,745 bill, stick-built, Penobscot, so 9 + 5 + 7 + 5 = 26 points):
  • (a) railroad_benefits $20,000.
    • Head: income 0, so 0% gives 1.30; 26 × 1.30 = 33.8, rounded up to 34; $748.
    • Counted: 20,000 / 15,650 = 127.80%, rounded to 128%, gives 0.80; 26 × 0.80 = 20.8, rounded up to 21; $462.
  • (b) railroad_benefits $40,000. Head $748. Counted: 40,000 > 36,836, and even after a standard 2026 Part B premium of $2,434.80 as a medical expense, 37,565.20 > 36,836, so $0.
  • The same figures hold for survivor_benefits.
• Severity: should. This is an omitted countable source with a wrong result in a claimed year (the wave's unpinned-or-omitted source precedent; Add Minnesota EAP Primary Heat benefit #10433 S1 for railroad annuities).
• Fix:
  • Add railroad_benefits and survivor_benefits to P/income/sources/unearned.yaml. Both count gross, like Social Security.
  • Add a railroad-only case like (a).
  • Update the body's unearned row and Axiom interpretation 8 and its countable-income output.

S2. TANF is left out on the plan's authority, although the rule's all-sources definition reaches it, while long-term disability is counted in 2025-26 on the rule's authority against the plan; neither choice is recorded

• Where:
  • P/income/sources/unearned.yaml:4-12: "disability_benefits stands for long-term disability payments, item (n) of the June 29, 2026 replacement; the 2025 edition's list 'includes, but is not limited to' the items it names", and "Not counted: TANF and General Assistance, which the rule does not list and the FY2026 plan's Section 1.9 leaves unchecked".
  • The body's "Not counted" row cites "Rule 3(C)(1) exclusions; Plan 1.9" for TANF, but neither exclusion list names TANF.
  • source_conflicts/candidates.yaml gets no entry.
• The rule.
  • Definition 1(EE) (2026 p. 3; 2025 edition the same): "'Household Income' means the total income from all sources before taxes and deductions as further defined in this Rule."
  • 3(C)(1) (p. 12): income of members over 18 "unless otherwise excluded from all sources before taxes and deductions", and the list "includes, but is not limited to" its items.
  • The exclusions (pp. 12-15, 2026 items a-t; the 2025 list is the same apart from items g and k) name SNAP, foster care, adoption assistance and "Non-cash income such as General Assistance voucher payments", but not TANF.
• The plan. Plan 1.9 (pp. 6-7, rendered) leaves "Temporary Assistance for Needy Families (TANF) benefits" unchecked. It also leaves "Insurance payments made directly to the insured" unchecked, and the 2025 edition's list does not name long-term disability (item (n) arrives only with the 2026 rule).
• What the PR does. It applies "includes, but is not limited to" to count long-term disability in 2025-26 against the plan box, and "the rule does not list" to drop TANF in line with the plan box. So the hierarchy runs one way for one source and the other way for the other.
• The project rule. CONTRIBUTING "Source conflicts": "Regulations are law"; "The agency breaks true ties" only where the text does not settle a reading. The rules file rates a plan-versus-regulation conflict should, with a clear recommendation (Add Missouri LIHEAP Energy Assistance #10438 S1).
• Effect (hand-traced, 2026; oil with a $1,745 bill, stick-built, Penobscot):
  • (a) TANF. Take T/me_heap_income.yaml Case 6 (head 27 with $2,400 of child support, tanf $10,740, children 5 and 2; categorically eligible), so 9 + 5 + 7 + 5 = 26 points.
    • Head: 2,400 / 26,650 = 9.01%, so 9% gives 1.30; 26 × 1.30 = 33.8, rounded up to 34; $748.
    • Rule: 13,140 / 26,650 = 49.31%, so 49% gives 1.20; 26 × 1.20 = 31.2, rounded up to 32; $704.
  • (b) Long-term disability, the other direction. A single adult aged 50 with is_disabled and disability_benefits $24,000: head 153.35%, so 153% gives 0.70 and 19 points, $418. Following the plan's box in 2025-26 gives 0%, 1.30 and 34 points, $748.
• Severity: should. Authoritative sources conflict, the PR applies the hierarchy inconsistently, and nothing records the choice.
• Fix: I recommend (a).
  • (a) Follow the rule for both. Count the SPM unit's tanf in me_heap_income (the rule's definition reaches it, and its exclusion list omits it), keep long-term disability, and add a us-me:heap-... candidate for the plan's unchecked TANF box with follows: rule and prs: [#10437].
  • (b) Follow the plan for both, pending a ruling from the project lead: keep TANF out, drop disability_benefits before June 29, 2026, and record the candidate with follows: plan.
  • Either way, correct the body's citation, and leave General Assistance out only on the voucher exclusion (j), saying so.

S3. Eligibility requires a fuel listed in the points matrix, which the rule does not, so OTHER-fuel households with their own bill get $0

• Where:
  • V/eligibility/me_heap_eligible.py:39-54 requires listed_fuel (eight heating_type values) unless the household is a subsidized heat-in-rent tenant.
  • V/payment/me_heap_points.py:33, 55 gives OTHER no fuel row.
  • T/eligibility/me_heap_eligible.yaml:54, 67-69 (Case 2) gives the OTHER household a $357 other_heating_fuel_expense, describes it as "a pellet stove", and pins it ineligible ("OTHER fails even with its pellet bill").
• Sources:
  • Eligibility. Rule 3(A)(4) (2026 p. 10) requires "a Direct Energy Cost or Indirect Determinable Energy Cost", and 3(B)(1)(a) (p. 11) requires "a Functioning Heating System". "Energy Cost" means "cost of energy used for heating" (1(Q), p. 2). Neither edition requires a fuel in the matrix.
  • Payment. Rule 5(A)(5) (2026 p. 17; the 2025 edition the same): "For payment for Primary Applicants that heat with Wood, Wood Pellets, Coal, Corn, or Bio-Fuel ... will make payment for a Benefit by direct check". The 2026 matrix has no corn or bio-fuel row, so the rule pays fuels its own table does not score.
  • MaineHousing's 2025-26 page lists the fuel types it accepts: "natural gas, heating oil, kerosene, propane, wood, wood pellets, biobricks, coal, corn, or electricity".
• Why this is not the UNSPECIFIED precedent. On Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303, Add Arizona LIHEAP Standard benefit #10293, Add Minnesota EAP Primary Heat benefit #10433 (G1) and Add Missouri LIHEAP Energy Assistance #10438 (G4), UNSPECIFIED $0 was accepted because heating_type is a required input. Here the caller supplies the input and a positive bill. heating_expense reads other_heating_fuel_expense for OTHER, which is how main represents a pellet, corn or bio-fuel household. The gate is the PR's inference from "the points matrix lists the fuels", not a rule requirement.
• Effect (hand-traced; a single adult aged 40, stick-built, Kennebec, OTHER with a $357 bill):
  • (a) 2026 (wages $30,472; 194.71%, rounded to 195%, gives 0.70). Head: $0.
    • Eligible with no fuel points: 9 + 2 = 11; 11 × 0.70 = 7.7, rounded up to 8; $176.
    • Scored on the wood-pellet row (5, also the corn row): 16 × 0.70 = 11.2, rounded up to 12; $264.
  • (b) 2027 (a corn stove; wages $31,408; 196.79% gives 0.70). Head: $0.
    • No fuel points: 8 + 3 + 1 = 12; 8.4 rounds up to 9; $198.
    • Wood-pellet row (4): 16 × 0.70 = 11.2, rounded up to 12; $264.
• Severity: should. This is a wrong result in a claimed year that contradicts the rule's eligibility test, with existing inputs, and a test pins it.
• Fix:
  • Drop listed_fuel from me_heap_eligible and keep the NONE exclusion (3(B)(1)(a)).
  • Score OTHER on the wood-pellet row (5 in the 2025 edition, matching corn; 4 in the 2026 rule), the listed fuel heating_type cannot name, or at 0 fuel points as a floor. Document the choice.
  • Re-pin eligibility Case 2 (OTHER becomes true) and add a points case for OTHER in each year. G1 covers UNSPECIFIED.
  • Update the body's eligibility row and Axiom interpretation 11.

S4. Nineteen income and expense entries, and one benefit branch, have no test that would fail if they were dropped

• Where: P/income/sources/earned.yaml (5 entries), P/income/sources/unearned.yaml (17), P/income/medical_expense_sources.yaml (2) and V/me_heap.py:43-48.
• Untested. No case gives these a positive value:
  • Earned (3 of 5): sstb_self_employment_income, farm_operations_income and self_employment_income. The last is set only to -$4,200 in income Case 4: that pins the floor, but dropping the source changes nothing.
  • Unearned (15 of 17): ssi (0 in every case), total_unemployment_compensation, workers_compensation, strike_benefits, alimony_income, veterans_benefits, financial_assistance, pension_income, military_retirement_income, disability_benefits, interest_income, ordinary_dividend_income, estate_income, rental_income and farm_rent_income.
    • Example: a single adult aged 66 whose only income is $20,000 of pension_income (oil, stick-built, Penobscot) gets $462. Dropping pension_income gives $748, and no case fails.
  • Medical (1 of 2): other_medical_expenses (0 in every case).
  • The public-housing branch of the $21 benefit. me_heap.py computes subsidized separately from me_heap_eligible. Eligibility Case 3 pins public housing only for eligibility, and me_heap.yaml Case 3 uses a voucher. If is_in_public_housing were dropped from me_heap.py, a public-housing tenant with heat in the rent (UNSPECIFIED, wages $30,472, Kennebec) would get 9 + 2 = 11 × 0.70 = 7.7, rounded up to 8, so $176 instead of $21, and no case would fail.
• Tested:
  • Income: wages, partnership and S corporation income, Social Security (retirement and disability), child support, IRA withdrawals (excluded), TANF (excluded) and health premiums.
  • Branches: every dwelling type, fuel and multiplier band in both years; base points; subsidized points; the priority edges at 6/7, 17/18 and 59/60; at-risk once; proration with the floating-point guard; the unlisted county; size 0; the limit edge; both sides of the medical adjustment; the student exclusion and its applicant exception; SNAP and TANF categorical eligibility; NONE; and no bill.
• Severity: should, as in Add Minnesota EAP Primary Heat benefit #10433 S2, Add Missouri LIHEAP Energy Assistance #10438 S5 and Add Washington LIHEAP regular heating assistance #10345 S4 (the mutation rule).
• Fix:
  • Add one me_heap_income case that gives every untested source a distinct positive amount for an adult. S1's railroad case covers railroad_benefits.
  • Give one medical-adjustment case a positive other_medical_expenses.
  • Add a me_heap.yaml case for a public-housing tenant with heat in the rent that expects $21.

Suggestions

G1. Unsubsidized heat-in-rent renters with an UNSPECIFIED fuel get $0.

• The model. me_heap_eligible denies an unsubsidized heat-in-rent tenant whose fuel is UNSPECIFIED (eligibility Case 3, household 3). main's HeatingType comment calls UNSPECIFIED "the right value when heat is included in rent and the tenant does not know the building's fuel".
• Example. Take T/integration.yaml Case 2 (2027, a family of four renting an apartment in Cumberland with heat in the rent, 0.9). With NATURAL_GAS it gets $374. With UNSPECIFIED it gets $0. Scored with no fuel points (8 + 1 + 1 + 5 = 15 × 0.9 = 13.5, rounded up to 14), it would get $308.
• The precedent. Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303, Add Arizona LIHEAP Standard benefit #10293, Add Minnesota EAP Primary Heat benefit #10433 G1 and Add Missouri LIHEAP Energy Assistance #10438 G4 settled UNSPECIFIED as an input rule, which is why this is a suggestion. S3's fix removes the gate for OTHER, so decide UNSPECIFIED explicitly: keep the gate and say so in the body, or score it at 0 fuel points or the lowest row (3 in 2027).

G2. The 2026-27 dollar value per point is an uncorroborated carry-forward.

• 2025-26 is well supported. Beyond the $1,012 = 46 × $22 identity, MaineHousing's 2025-26 notice reports "approximately 4,000 households have received assistance, totaling $2.2 million" (about $550, roughly 25 points at $22 for priority households). The August 2026 board packet reports $20,625,130 paid for PY2026 (p. 67).
• 2026-27 is not. The new matrix runs from 10 × 0.7 = 7 points ($154) to 30 × 1.8 = 54 points ($1,188) at $22. The only FY2027 figures MaineHousing has printed, item 2.6 of the draft FFY2027 plan (April 2026 board packet, p. 110, rendered), are $88 and $1,012, both flagged with the comment "Get this information". The adopted plan went to HHS by August 21, 2026 (August packet, p. 67) and is not yet on the Clearinghouse.
• Fix:
  • Note the draft's placeholders, and the fact that the model's 2027 maximum exceeds them, in P/payment/value_per_point.yaml and the body (Axiom interpretation 1 already does).
  • Re-derive the value when the adopted FFY2027 plan or an announcement appears. Until then, consider saying in programs.yaml that 2027 benefit amounts are estimates while 2027 eligibility is verified.

G3. Count me_ssp (checklist item 17) and Maine paid family and medical leave benefits.

• me_ssp. It is on main (in this PR's base), and the rule's "total income from all sources" reaches it: the State Supplement is cash income, and no exclusion names it.
  • Example: an SSI recipient living alone receives $10 a month ($120 a year). For a 2026 household whose countable income sits at $11,700 (74.76%, rounded to 75%, so 1.10), adding $120 gives 75.53%, rounded to 76%, so 1.00. On 26 points that is 29 points, $638, against 26 points, $572.
• pfml_benefits. Maine's paid family and medical leave benefits became payable on May 1, 2026, and main has the pfml_benefits input. The rule counts unemployment insurance and long-term disability and does not exclude leave benefits.
• Fix: add both to the unearned list, with a case each. Otherwise, explain in the body why they are left out.

G4. Record the plan-versus-rule and plan-versus-chart readings in the body and the backlog.

• The readings. Axiom interpretations 3, 4, 6 and 13 record these choices, but the body and source_conflicts/candidates.yaml do not:
  • Categorical households. Plan 1.4a and 1.6 (p. 5, rendered) say these households "will have their benefit calculated based on the highest FPL allowable for each benefit type above", unless they choose to document actual income. The PR uses actual income, which rule 3(C)(2) also allows.
  • Size 10. Plan 2.1 (p. 9) assigns size 10 to "HHS Poverty Guidelines 150.00%" ($97,725). The 2025-26 chart prints $102,008 (60% of SMI), and the PR follows the chart.
  • At-risk points. The April 2026 proposed-rule memo says the new matrix "will add points for additional at-risk household members" (p. 66). The adopted table prints only "Points for the first in the house", and the PR follows the table.
  • Members over 18. The PR counts members aged 18 and older under "over the age of 18". Plan 1.9's unchecked "Earned income of a child under the age of 18" box supports that reading; say so in the body.
• Fix:
  • Add a us-me:heap-... candidate for the categorical and size-10 readings with prs: [#10437], as us-al:liheap-lump-sums-and-refunds and us-sd:liheap-cash-gifts do (Add Minnesota EAP Primary Heat benefit #10433 G3, Add Missouri LIHEAP Energy Assistance #10438 G2).
  • Note the at-risk memo in the body.
  • Change the body's "the HEAP Guide is not public" to say that it was posted and is no longer available. Asking MaineHousing for the PY2026 or PY2027 Guide could settle the income period, the categorical percentages and unlisted fuels.

G5. Add Wayback captures for three URLs that MaineHousing or the Secretary of State overwrite.

• The rule PDF. .../msha-rules/ch24-home-energy-assistance-program-rule.pdf held the 2025 edition until the June 29, 2026 rule replaced it, and it will be replaced again. Every 2026-rule anchor (pages 10-17) would then drift.
• The Word copy. The Secretary of State's 346c024.docx still holds the 2025 edition (filing history ends "2025-135"). It should soon be replaced by filing 2026-134, leaving every 2025-edition reference pointing at the wrong edition.
• The chart. mainehousing.org/charts/ shows the 2026-27 chart (modified 2026-07-22) and is replaced each season.
• Fix: add a dated capture beside each, as Add Minnesota EAP Primary Heat benefit #10433 G6 and Add Missouri LIHEAP Energy Assistance #10438 G5 asked. The 2025-26 chart already uses one.

G6. Reconsider the stick-built default for me_heap_dwelling_type.

• The default. V/me_heap_dwelling_type.py:14 defaults to STICK_BUILT_OR_MODULAR, the highest dwelling row in both editions. In microsimulation every household, renters and heat-in-rent tenants included, gets it.
• Example. A 2026 unsubsidized heat-in-rent renter (natural gas, Cumberland, wages $30,472, 0.70) gets 9 + 3 + 5 = 17 × 0.70 = 11.9, rounded up to 12, so $264 with the default, against 14 × 0.70 = 9.8, rounded up to 10, so $220 as an apartment.
• Fix: derive the default from tenure (renters and heat-in-rent tenants as CONDO_DUPLEX_OR_APARTMENT), as Add Minnesota EAP Primary Heat benefit #10433 G4 suggested for Minnesota's HOUSE default. Otherwise, state the effect in the variable documentation and the body.

Verified correct

Values against sources:

• Points, 2025 edition (FY2026 matrix pp. 1-2; the SOS Word copy is identical):
  • stick-built/modular 9, mobile/manufactured 8, condo/duplex and apartment 6;
  • all 16 counties (Aroostook 7; Somerset, Franklin and Piscataquis 6; Oxford and Penobscot 5; Androscoggin and Hancock 4; Waldo, Cumberland, Lincoln, Knox and York 3; Washington, Kennebec and Sagadahoc 2);
  • electricity 14, LP gas 10, kerosene 8, oil 7, coal 5, natural gas 5, wood 4;
  • "Responsible for Heating" -9;
  • "60+, Disabled or child 6 and under" 5, "or" child 7-17 3;
  • the seven bands (130% down to 70% "not exceeding the maximum of the greater of 150% FPIG or 60% state median income");
  • the rounding examples ("75.1% will be rounded to 75%; income at 100.6% will be rounded to 101%") and "All final point results that are fractional will be rounded up".
• Points, June 29, 2026 rule (pp. 16-17; effective date p. 33):
  • base 8; dwelling 3/2/1/1;
  • counties (Aroostook 6; Franklin 5; Somerset, Piscataquis, Oxford, Hancock and Washington 4; Sagadahoc, Penobscot and Waldo 3; Androscoggin, York, Knox and Lincoln 2; Cumberland and Kennebec 1);
  • electric 8, LP gas 5, kerosene 5, oil 4, coal 4, natural gas 3, wood 3;
  • at-risk 5 "for the first in the house" and no older-child row; heating subsidized -3;
  • bands 0-10.99% 1.8, 11-33.99% 1.6, 34-75.99% 1.4, 76-100.99% 1.2, 101-125.99% 1, 126-150.99% 0.9, 151-175.99% 0.8 and >176% 0.7.
  • Rounding half up to hundredths, and 0.7 at exactly 176.00%, are documented readings of a rule with no rounding sentence.
• Income limit (rule 3(C), p. 11; 2025-edition 70% row; 42 U.S.C. 8624(b)(2)(B)):
  • SMI. $118,065 (FFY2026) and $122,022 (FFY2027) on main give 70,839 and 73,213 at 60%.
  • 2025-26 chart, all 10 rows: 36,836, 48,170, 59,504, 70,839, 82,173, 93,507, 95,632, 97,757, 99,882 and 102,008.
  • 2026-27 chart, all 10 rows: 38,070, 49,784, 61,498, 73,213, 84,927, 96,641, 98,837, 101,033, 103,230 and 105,426.
  • 150% of the lagged guideline binds from size 11 in 2026 (105,975 against 104,133), as plan 2.1 assigns sizes 11-12. The 110% floor never binds.
• Dollar amounts:
  • $22 a point for 2025-26 (plans 2.6, FY2025 p. 8 and FY2026 p. 10: $88 and $1,012);
  • $21 subsidized heat-in-rent (plan 1.7b, p. 5, rendered: "$21.00", "Once Per Year"; rule 4(C) of the 2025 edition and 4(B) of the 2026 rule; the draft FFY2027 plan repeats $21.00).
• Countable income (plan 1.8 "Gross Income"; rule 3(C)(1), pp. 11-15):
  • Social Security and SSI gross "including Medicare deductions", with plan 1.9's "Including MediCare deduction" box checked. The Part B premium enters only through the over-income medical adjustment.
  • Medical adjustment. It uses medical_expense_health_insurance_premiums (modeled Part B for enrollees plus other premiums) and other_medical_expenses. Excluding pre_tax_health_insurance_premiums matches Publication 502 ("Don't include in your medical and dental expenses any insurance premiums paid by an employer-sponsored health insurance plan unless the premiums are included on your Form W-2"), and "Premiums you pay for Medicare Part B are a medical expense". It stops at the limit, as "equal to only the amount necessary to make the Household eligible" requires.
  • Loss floors. A per-source floor on all 22 sources, so neither business nor rental losses offset wages (the wave's losses precedent passes).
  • Exclusions: retirement drawdowns ("Assets drawn down from financial institutions"); a full-time high-school student who is not the Primary Applicant (tax-unit head proxy); capital gains, refunds and SNAP.
  • Members: under 18 excluded; the income of members outside the counted size included (p. 15).
• Eligibility:
  • size counts is_citizen_or_legal_immigrant (3(A)(1), p. 6), and size 0 is ineligible;
  • categorical SNAP or TANF (3(C)(2); plan 1.4: TANF and SNAP "Yes", SSI "No", rendered);
  • a Direct or Indirect Determinable Energy Cost (3(A)(4)) through has_heating_expense or heat_expense_included_in_rent;
  • NONE fails the functioning-heating-system test (3(B)(1)(a));
  • subsidized heat-in-rent tenants qualify (3(B)(3));
  • Subsidized Housing is receives_housing_assistance or is_in_public_housing, a documented subset of 1(VV).
• Benefit formula (4(A)): points × multiplier × counted share of members, rounded up, × value. FLOAT_GUARD_DECIMALS is a numerical tolerance, documented as such, and Case 10 pins 22.000000000000004 to 22.
• Years:
  • 2026 and 2027 are verified, apart from G2.
  • Earlier years. Parameters start 2024-07-03 or 2024-10-01, so period 2025 and earlier take the 2025-edition values. That is right for the 2024-25 season (same matrix, same $1,012 plan maximum) and an unclaimed, documented backfill before it (verified_years: "2026-2027"; NJ S3 pattern).

Hand-checked expectations (24). All are 2026 unless noted:

• Income limit Case 1: floor(0.6 × 118,065) = 70,839; 70,839 × 0.52 = 36,836.28, giving 36,836 (150% is 23,475).
• Income limit Case 2: size 10, factor 1.44, 102,008.16 gives 102,008 (150% = 97,725); size 11, 1.47 gives 104,133 against 150% × 70,650 = 105,975.
• Income limit Case 3 (2027): floor(0.6 × 122,022) = 73,213; × 0.52 = 38,070.76, giving 38,070; size 4 73,213.
• Eligibility Case 1: 36,836 is eligible, 36,837 is not, and 36,837 with SNAP is eligible.
• Eligibility Case 3: voucher and public housing with heat in the rent are true; unsubsidized UNSPECIFIED is false (G1); unsubsidized natural gas is true; NONE is false.
• Eligibility Case 4: TPS and undocumented give size 0, limit 0, false.
• Income Case 1: 30,472 (the 18-year-old student and the 17-year-old excluded).
• Income Case 2: 15,236 + 22,854 = 38,090.
• Income Case 4: 19,045 + max(-4,200, 0) + 8,000 = 27,045.
• Income Case 7: 30,472 + 11,427 = 41,899, with size 2.
• Income Case 8: 38,948 > 36,836; 38,948 - 2,220 = 36,728, so the result is 36,836 and eligible.
• Income Case 9: 42,757 - 2,220 = 40,537, ineligible.
• Multiplier Case 1: 3,975.10 / 15,650 = 25.40%, rounded to 25%, gives 1.3; 3,990.75 / 15,650 = 25.50%, rounded to 26%, gives 1.2.
• Multiplier Case 2: 74.15%, 97.35%, 121.15%, 146.03% and 194.71% give 1.1, 1.0, 0.9, 0.8, 0.7.
• Multiplier Case 3 (2027, guideline 33,000): 10.99% / 11.00% give 1.8 / 1.6; 75.99% / 76.00% give 1.4 / 1.2; 175.99% / 176.00% give 0.8 / 0.7.
• Points Case 3: 11 plus each fuel gives 25, 25, 21, 19, 18, 16, 16, 15. Case 4 (2027): 12 plus each fuel gives 20, 20, 17, 17, 16, 16, 15, 15.
• Points Case 6: 18 plus 5 / 3 / 3 / 0 gives 23, 21, 21, 18. Case 7 (2027): 16, 21, 21.
• Points Cases 8-9: 22 - 9 = 13 (voucher and public housing), 22; 2027: 18 - 3 = 15, 18.
• Points Case 10: 22,854 / 32,150 = 71.09%, rounded to 71%, gives 1.1; 25 × 1.1 × 4/5 = 22, so $484.
• Points Case 11 (2027): 31,408 / 21,640 = 145.14% gives 0.9; 21 × 0.9 × 2/3 = 12.6, so 13 and $286.
• me_heap Case 1: IRA excluded, income 0, 1.3; 35 × 1.3 = 45.5, so 46 and $1,012.
• me_heap Case 2 (2027): 24,852 / 15,960 = 155.71% gives 0.8; 18 × 0.8 = 14.4, so 15 and $330.
• Integration Cases 1-3:
  • Case 1: 23,712 / 15,650 = 151.51%, rounded to 152%, gives 0.7; 26 × 0.7 = 18.2, so 19 and $418.
  • Case 2 (2027): 47,112 / 33,000 = 142.76% gives 0.9; 18 × 0.9 = 16.2, so 17 and $374.
  • Case 3: 25,254 / 26,650 = 94.76%, rounded to 95%, gives 1.0; 6 + 7 + 10 + 5 - 9 = 19, so $418.
• Case count: 2 + 4 + 3 + 4 + 4 + 1 + 9 + 4 + 12 = 43, as the body says.

Batch checks:

• Integrate modeled state unemployment insurance into income flows #9558: the list reads total_unemployment_compensation, and the guard passed in CI (unpinned, S4).
• Count military SBP annuities in state benefit income lists #10317 / Wire military retirement pay and survivors into federal and state tax (#10181) #10182 (item 16): the list reads military_retirement_income, so retired pay and SBP annuities count, and the guard passed.
• Count each Social Security benefit once in Pennsylvania CCW countable income #10408 (still open): Social Security is read once as social_security. No component appears in any list, and disability_benefits excludes Social Security. S1's survivor_benefits (non-Social Security) and railroad_benefits would stay disjoint.
• Document disjoint health premium inputs and correct consumer treatment #10046 (item 14): pass. Wages count gross, and the medical list leaves out payroll premiums, as Publication 502 does.
• Tie source-conflict markers to the register shared with Axiom #10287 ratchet:
  • It passed in CI. The run started 2026-10-23 22:17 UTC, after Tie source-conflict markers to the register shared with Axiom #10287 and the 2026-10-21 cutoff.
  • On the merged tree I ran main's CONFLICT_COMMENT_RE over the comments the PR adds to its parameter and variable files (178 comment lines): 0 matches and no markers.
  • The PR adds no candidate.
• State-gated keys (item 15): safe.
  • me_heap_dwelling_type is an ungated enum whose default is in the breakdown.
  • County lookups route unlisted counties (UNKNOWN or another state's) to a listed key and then zero them (points Case 12).
  • Fuel points use select, and me_heap_household_size feeds only arithmetic.
  • Eligibility Case 2 includes a New Hampshire household, and the Microsimulation job passed.
• IIJA / FY2027 (item 12): no IIJA supplement is modeled (Supplemental Benefits are out of scope). FY2027 rests on the June 29, 2026 rule and the 2026-27 chart; the FY2027 plan is not posted (G2).
• Item 17 (state SSP): me_ssp is on main and in the base, and the rule's all-sources definition reaches it, but the list omits it (G3).

Wiring and housekeeping:

• Registry. The ME entry sits between MD and MS with verified_years: "2026-2027", and ME is added to the coverage line. test_programs_registry passed.
• Aggregates. There is no aggregate wiring, which matches every merged LIHEAP state.
• Gating. defined_for = StateCode.ME is on 7 variables, and me_heap is gated by me_heap_eligible. test_members_are_state_gated passed.
• Changelog. changelog.d/me-liheap-wave1d.added.md is top level and typed added.
• Shared parameter. gov.hhs.liheap.fpg_limit (1.5 from 1981-10-01) matches 42 U.S.C. 8624(b)(2)(B)(i). The Vermont branch's copy is byte-identical, so the two merge cleanly.
• Descriptions (item 6): all 20 end "under the Low Income Home Energy Assistance Program." with nothing after it.
• References (item 7):
  • Every anchor I opened shows its value: rule pp. 10, 11, 11-12, 11-13, 15, 16 and 17; matrix pp. 1, 2 and 1-2; plan pp. 5, 6-7, 9 and 10; FY2025 plan p. 8.
  • Multi-page titles use the quoted #page 11-12 form, and variables use # PDF pages comments.
  • Wayback captures are G5.
• Tests. The files are variable-named, every period is plain, and every eligibility or benefit case sends heating_type.

Checklist results (LIHEAP batch):

1. State plan and rule: every matrix cell, limit row and dollar amount matches. The 2026-27 point value is G2.
2. Income definition: gross income, Social Security gross (Maine's rule), per-source floors and the medical adjustment are right. Omitted annuities are S1; TANF and long-term disability are S2.
3. Backdating: pass for 2026-2027. Earlier years are a documented, unclaimed backfill.
4. Household and arrangement rules: heat in rent (subsidized and unsubsidized), subsidized points and categorical eligibility are right. The listed-fuel gate is S3, UNSPECIFIED is G1 and the dwelling default is G6.
5. Tests: 43 cases, 24 hand-checked, all periods plain. Source coverage is S4.
6. Descriptions: pass.
7. References: pass (Wayback captures are G5).
8. Wiring: pass.
9. Axiom: valid (Add DC TANF maximum income #1898).
10. Branch and CI: a clean merge with main; 27 pass and 3 skipping.
11. Integrate modeled state unemployment insurance into income flows #9558: pass.
12. IIJA / FY2027: not applicable / FY2027 from the June 29, 2026 rule and chart.
13. Mutation check: 19 entries and one branch are unpinned (S4).
14. Document disjoint health premium inputs and correct consumer treatment #10046: pass.
15. State-gated index defaults: safe.
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.
17. Merged state SSPs: me_ssp not counted (G3).

Axiom line assessment

Valid: axiom: TheAxiomFoundation/rulespec-us#1898 queued.

• State: OPEN, labelled pe-parity, created 2026-10-23 22:16 UTC.

• It matches the head. It names head bbdb9b5f78 and merge base 6a92d6a983. It lists the 43 cases by file. Its required outputs (size, limit, countable income with the same 5 earned and 17 unearned sources, categorical eligibility, multiplier, points, eligibility and benefit) describe the head's code.

• It is dispatch-ready in the rulespec-us#1467 format:

  • proposed us-me/ module paths, with corpus status per source;
  • verbatim text of both rule editions, the plans and both charts;
  • companion tests derived from the sources, not from PE output;
  • 16 interpretations;
  • its blockers: sources missing from the corpus, no published point value, an unchecked signed release, billed-run approval and no reviewed oracle revision.

• Note. The fixes change these interpretations and outputs:

  • S1 and S2 change interpretation 8 and the countable-income output;
  • S3 and G1 change interpretation 11 and the eligibility and points outputs;
  • S4 adds cases;
  • G2 changes interpretation 1;
  • G3 changes interpretation 8;
  • G6 changes interpretation 14.

  Update the issue with the head that resolves them.

CI status

27 pass, 0 failed, 3 skipping, none pending. I re-checked gh pr checks 10437 at the end of this review.

• The runs. Run 40032620248 tested head bbdb9b5f78 (pull_request, created 2026-10-23 22:17 UTC, after Tie source-conflict markers to the register shared with Axiom #10287, the 2026-10-21 cutoff and Count military SBP annuities in state benefit income lists #10317, which is in the base). The three skipped checks belong to an earlier trigger on the same head (run 40032382104, 22:15 UTC).
• Maine tests. States-shard-3, batch 6/13 (states/me, 80 files, exit 0), ran all 9 files: 2 + 4 + 3 + 4 + 4 + 1 + 9 + 4 + 12 = 43 passed.
• Guards (Rest shard-1):
  • the four test_unemployment_compensation_readers.py tests;
  • the four test_military_retirement_readers.py tests;
  • the test_source_conflicts.py 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, and every baseline and contrib shard.
• Known main-caused failure: not applicable.
• Locally: I ran no tests or model probes. The S1-S4 and G1-G6 examples are hand traces of the code at the head. The only local scripts were text extraction and page renders of the sources and the static comment-pattern scan.

Branch status

• Position: 2 commits ahead of main (9ee14cdb43; one of them merges main at 6a92d6a983) and 41 behind.
• Merge: clean. git merge-tree --write-tree PolicyEngine/main bbdb9b5f78 exits 0.
• Main's 41 newer commits touch no Maine HEAP dependency:
  • the SMI and guideline values, the heating, housing, Medicare, immigration, tanf, snap and me_ssp inputs are unchanged;
  • the county-helper change adds a state-FIPS lookup for local sales tax;
  • the ratchet's baseline edits do not involve this PR's files.
• Coverage line. This PR adds ME to the LIHEAP coverage line.
• Sibling conflicts (branch note). A trial merge with each open LIHEAP PR conflicts only in policyengine_us/programs.yaml.
  • The conflicting PRs are Add Pennsylvania LIHEAP regular heating assistance #9971 (PA), Add Virginia EAP Fuel Assistance (LIHEAP regular heating) #10303 (VA, which carries the coordinated AZ / IA / VA coverage line), 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 Nevada Energy Assistance Program Fixed Annual Credit #10432 (NV), Add Minnesota EAP Primary Heat benefit #10433 (MN), Add Wisconsin WHEAP regular heating benefit #10434 (WI), Add Montana LIHEAP regular heating assistance #10435 (MT), Add Vermont Seasonal Fuel Assistance #10436 (VT) and Add Missouri LIHEAP Energy Assistance #10438 (MO).
  • Add Arizona LIHEAP Standard benefit #10293 (AZ) merges cleanly.
  • Whichever lands first, the rest need a one-line resolution.

0 critical, 4 should and 6 suggestions are open at this head.

Verdict: REQUEST_CHANGES

[DTrim99]

Every points-matrix cell matches its edition, the income limit reproduces all 20 published chart rows, $22 a point and the $21 subsidized amount check out, Social Security correctly counts including Medicare deductions (rule 3(C)(1)(c)), and 24 expectations hand-check. Four should-address items: (1) railroad and survivor annuities aren't counted, though rule 3(C)(1)(i) counts regular annuities ($748 vs $462 for a $20k railroad retiree); (2) TANF follows the plan over the rule while long-term disability follows the rule over the plan, unrecorded; (3) eligibility requires a listed fuel, which the rule doesn't, so OTHER-fuel households get $0; (4) 19 income and expense entries and the public-housing branch are untested. Six suggestions. Full report in the comment above.

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[hua7450]

Thanks, David. Round 1 is in 7d4e4569a0; cc78d48246 merges current main, which now has gov.hhs.liheap.fpg_limit from #10342, so this PR no longer adds that file.

• S1. income/sources/unearned.yaml now counts railroad_benefits and survivor_benefits, gross, as rule 3(C)(1)(i) "regular annuity payments". Your railroad retiree with $20,000 gets $462 (was $748), and with $40,000 gets $0 (was $748). Income Case 11 gives both sources distinct amounts, so dropping either changes its total.
• S2. I took your option (a), so the rule governs both sources. me_heap_income.py adds the unit's take-up-gated tanf to gross income once, and long-term disability stays counted. Income Case 6 now expects $13,140 (was $2,400), which gives that family $704 in 2026 (was $748). General Assistance stays out only as non-cash voucher income (exclusion (j)), and the body's "Not counted" row now cites the rule's exclusions alone. source_conflicts/candidates.yaml records the choice as us-me:liheap-tanf-and-disability-income (follows: statute).
• S3. eligibility/me_heap_eligible.py drops the listed-fuel gate. NONE stays ineligible (3(B)(1)(a)), and UNSPECIFIED qualifies only with subsidized heat in rent (G1). OTHER with its bill is eligible and scores 0 fuel points. heating_type cannot tell these fuels apart, and their rows differ (bio-fuel and biobricks 6, wood pellets 5 and corn 5 in the 2025 edition; wood pellets 4 and biobricks 3 in the 2026 rule, which has no corn or bio-fuel row), so 0 is the floor. Eligibility Case 2 now expects the pellet household to be eligible, and new me_heap.yaml Case 6 pays your 2026 example $176 (was $0). Your 2027 corn example ($198) takes the same branch, so I did not add a second case. The comments in payment/me_heap_points.py, points/fuel.yaml and me_heap.py now describe OTHER.
• S4. Four new cases pin the entries and the branch:
  • Income Case 10 gives the three remaining earned sources $3,000, $2,000 and $1,000, for 6,000. Dropping any one gives 3,000, 4,000 or 5,000.
  • Income Case 11 gives each of the 18 unearned sources not pinned elsewhere a different multiple of $100 (17,100), plus $120 of me_ssp: 17,220.
  • Income Case 12 adds $4,000 of other_medical_expenses to Case 9's household, which then reaches the limit: 36,836 and eligible (40,537 without it).
  • me_heap.yaml Case 5 pays a public-housing tenant with heat in the rent $21. Without is_in_public_housing in me_heap.py, the case would pay 6 x $22 = $132.
• G1. Declined. heating_type is a required input, and UNSPECIFIED pays $0 except with subsidized heat in rent; Default heating_type to electricity and remove the UNSPECIFIED-gated state heating adapters #9754 tracks the default. The S3 code keeps that exception explicit, and eligibility Case 3 still expects the unsubsidized UNSPECIFIED tenant to be ineligible.
• G2. The $22 stays for 2026-27 because no newer figure is published: the FFY2027 plan is not on the Clearinghouse, and the October 2026 board packet expects the Notice of Award by the end of October. payment/value_per_point.yaml now cites the draft FFY2027 plan (April 2026 board packet, page 110) with its placeholder $88 and $1,012, and notes that the June 29, 2026 matrix pays $110 to $1,188 at $22. The programs.yaml note already calls the $22 an estimate. A published value would replace it.
• G3. income/sources/unearned.yaml adds me_ssp after ssi and pfml_benefits after disability_benefits. No exclusion names either. Income Case 11 pins both ($120 of SSP and $1,800 of PFML). Your $11,700 example now pays $572 (was $638).
• G4.
  • us-me:liheap-size-ten-income-limit (follows: statute) records size 10. The model follows the 2025 edition's 70% row and the chart ($102,008) over plan 2.1 ($97,725).
  • The categorical reading has no candidate because rule 3(C)(2) permits "actual vetted income". eligibility/me_heap_categorically_eligible.py says so, and the body notes that plan 1.4a's percentages would come from the HEAP Guide.
  • The body also adds three notes. The April 2026 memo proposed points for additional at-risk members, but the adopted table prints "Points for the first in the house". Plan 1.9's unchecked child-earnings box supports counting members aged 18. MaineHousing posted the PY2026 HEAP Guide, and the file now returns 404.
• G5. Done for the chart. eligibility/me_heap_income_limit.py and income/medical_expense_sources.yaml now cite the 2026-27 chart through the October 15, 2026 capture of the HEAP page. Declined for the rule references. Wayback has no capture of the June 29, 2026 rule PDF or of the Secretary of State's Word copy. Its July 22, 2025 capture of the rule PDF holds the 2025 edition, but it is a different document from the Word copy that the 23 references cite. The size-ten candidate cites that 2025 capture.
• G6. Declined. The house default (stick-built or modular here) is the all-state LIHEAP convention, and the variable documentation and the body already state it.

The PR body and TheAxiomFoundation/rulespec-us#1898 now describe this head.

I did not run the tests locally; CI passed every check at cc78d48246.

[DTrim99]

PR Review (round 2): Add Maine HEAP Fuel Assistance

PR #10437 (author: hua7450), head cc78d48246. Round 1 (2026-10-27, head bbdb9b5f78) requested changes for 4 should-address items and 6 suggestions. Since then the author has pushed:

• a fix commit, 7d4e4569a0 (595 diff lines);
• a merge of main at c55b806541 with two hand-resolved blocks. In gov.hhs.liheap.fpg_limit the branch takes the copy that main gained from Add North Dakota LIHEAP regular heating assistance #10342. The programs.yaml LIHEAP coverage line keeps main's 31 entries and adds ME.

Path prefixes:

• P/ = policyengine_us/parameters/gov/states/me/msha/heap/
• V/ = policyengine_us/variables/gov/states/me/msha/heap/
• T/ = policyengine_us/tests/policy/baseline/gov/states/me/msha/heap/

Summary

All four round-1 should-address items are fixed, and each fix is pinned by a test that would fail without it.

• S1. Railroad and non-Social Security survivor annuities now count.
• S2. TANF counts under the rule, and long-term disability stays counted. A candidate records the choice.
• S3. OTHER fuel with a bill is now eligible.
• S4. Every earned and unearned source, other_medical_expenses and the public-housing branch of the $21 benefit are pinned.

Suggestions.

• G3 (Maine SSP and paid family and medical leave) and G4 (candidates and body notes) are done, and G2 is documented.
• G1 and G6 are declined with reasons that match the wave.
• G5 is done for the income chart. The two rule documents still have no dated capture.

One new should-address item, introduced by the S3 fix.

• N1. OTHER scores 0 fuel points. Under the 2025-edition matrix (model year 2026), that combines with the -9 subsidized-heating points to give negative or zero benefits.
• Take an apartment tenant with a Housing Choice Voucher who pays a pellet bill in Kennebec. The model pays -$22. The rule's pellet row would pay $110.
• The rule's own matrix never scores below 3 points.

Status.

• Axiom: rulespec-us#1898 is OPEN, labelled pe-parity, and was updated to this head on 2026-10-29.
• CI: 35 of 35 checks pass at this head, and all 48 Maine HEAP cases ran.
• Branch: the PR now conflicts with main in programs.yaml (AK Add Alaska LIHEAP regular heating assistance #10341 has added AK to the coverage line) and source_conflicts/candidates.yaml (Extend Maine's childless EITC expansion to 2021 students aged 19 to 23 #10526). Both are one-block resolutions (branch note).

0 critical, 1 should and 1 suggestion are open.

Prior findings

Finding	Status	Evidence
S1. Railroad and survivor annuities not counted	Fixed	P/income/sources/unearned.yaml:34-35 adds railroad_benefits and survivor_benefits (item (i), "regular annuity payments"). T/me_heap_income.yaml Case 11 (line 386) gives them $1,600 and $1,700, so dropping either turns 17,220 into 15,620 or 15,520. The round-1 retiree with $20,000 of railroad income: 20,000 / 15,650 = 127.80%, rounded to 128%, gives 0.80; 26 × 0.8 = 20.8, rounded up to 21, so $462. Neither input is part of social_security (its four components) or pension_income on main, so nothing is counted twice.
S2. TANF follows the plan, long-term disability follows the rule, and neither choice is recorded	Fixed (option (a))	V/me_heap_income.py:38-42 adds the unit's take-up-gated tanf once (tanf sums STATE_TANF_VARIABLES, which include me_tanf). Income Case 6 (line 209) expects 13,140, and dropping the term gives 2,400. The 2026 rule's exclusions (pp. 13-14, items a-t) name "One-time insurance payments" (h) and "Non-cash income such as General Assistance voucher payments" (j) but not TANF, so the reading is right. Candidate us-me:liheap-tanf-and-disability-income has follows: statute and state: ruled; the file header defines ruled as "PolicyEngine has picked". The body now cites the rule's exclusions alone.
S3. Eligibility requires a fuel listed in the matrix	Fixed for eligibility; see N1	V/eligibility/me_heap_eligible.py:41 replaces listed_fuel with known_fuel = (fuel != UNSPECIFIED) | (heat_in_rent & subsidized). Eligibility Case 2 (line 71) now expects OTHER with its $357 pellet bill to be true. T/me_heap.yaml Case 6 pays $176 (9 + 2 + 0 = 11; 11 × 0.7 = 7.7, rounded up to 8; 8 × $22). The 0-point floor was one of round 1's options, but it interacts with the subsidized points (N1).
S4. Untested sources and the public-housing branch	Fixed	Income Case 10 (line 342): 3,000 + 2,000 + 1,000 = 6,000, and dropping one source gives 3,000, 4,000 or 5,000. Case 11 (line 386): 100 × (1 + ... + 18) = 17,100 plus $120 of SSP = 17,220, with a distinct amount per source. Case 12 (line 422): 42,757 - (2,220 + 4,000) = 36,537, which is floored at the 36,836 limit, so the household is eligible; without other_medical_expenses it gets 40,537 and is ineligible. T/me_heap.yaml Case 5 (line 202) pays a public-housing tenant $21; without is_in_public_housing in me_heap.py it pays 6 × $22 = $132.
G1. UNSPECIFIED heat-in-rent renters get $0	Declined, accepted	This is the wave convention (#9754): UNSPECIFIED pays $0 except for subsidized heat in rent. The exception is explicit in known_fuel, and eligibility Case 3 (line 93) still pins the unsubsidized UNSPECIFIED tenant as ineligible.
G2. The 2026-27 value per point is uncorroborated	Addressed (documented)	P/payment/value_per_point.yaml:9-17 notes the draft FFY2027 plan's placeholder $88 and $1,012 and adds that plan (April 2026 board packet, p. 110) as a reference. The programs.yaml note calls the $22 an estimate. No newer figure is published, so this stays an estimate until MaineHousing announces one.
G3. me_ssp and paid family and medical leave	Fixed	P/income/sources/unearned.yaml:20, 39, pinned by Case 11. me_ssp is a monthly Person variable on main, and SNAP's unearned list also counts ssi and me_ssp separately, so nothing overlaps. pfml_benefits is read elsewhere only by Massachusetts CCFA. Round 1's $11,700 example: 11,820 / 15,650 = 75.53%, rounded to 76%, gives 1.00; 26 points, $572.
G4. Record the plan-versus-rule readings	Fixed	Candidates us-me:liheap-size-ten-income-limit and us-me:liheap-tanf-and-disability-income are added. V/eligibility/me_heap_categorically_eligible.py:17-21 cites 3(C)(2)'s "actual vetted income". The body adds notes on the at-risk memo, plan 1.9's child-earnings box and the HEAP Guide that returns 404.
G5. Wayback captures for overwritten URLs	Partly fixed; the rest stays a suggestion	The 2026-27 chart now cites the October 15, 2026 capture of the HEAP page. The Wayback index lists it as a 200 capture. I could not open its contents (automated fetches are blocked), but the live page shows "Income Limits 2026 - 2027 Season" with all 10 rows ($38,070 to $105,426). For the two rule documents, the author's reason checks out: the index holds only a July 22, 2025 capture of the rule PDF and none of the Secretary of State's Word copy. The Word copy still holds the 2025 edition (its filing history ends "2025-135 ... July 1, 2025"), so nothing has drifted yet. A Save Page Now capture could still be made (see G5 below).
G6. Stick-built default for me_heap_dwelling_type	Declined, accepted	The default is documented in the variable (V/me_heap_dwelling_type.py:17-22) and in the body, and it matches the house LIHEAP dwelling default.

New findings

Critical

None.

Should address

N1. The S3 fix's 0-point OTHER row makes 2025-edition points negative or zero for subsidized households that pay their own heat

• Where:

  • V/payment/me_heap_points.py:38-58: the fuel select gives OTHER default=0.
  • :80: subsidized households not on heat-in-rent get -9 under the 2025 edition.
  • :96: np.ceil(...) with no floor.
  • V/me_heap.py:50-54: the benefit is points * value_per_point, also with no floor.
  • No test has a subsidized OTHER household.

• Sources:

  • 2025-edition matrix (FY2026 Benefit Matrix, pp. 1-2): the lowest rows are condo/duplex/apartment 6, Kennebec, Sagadahoc and Washington 2, wood 4 (pellets 5, corn 5, bio-fuel 6), and "Subsidized Household, Responsible for Heating" -9.
  • Lowest possible score. For any fuel the rule scores, that is 6 + 2 + 4 - 9 = 3. P/payment/value_per_point.yaml:7 says the same: "the matrix's smallest award is 3 points".
  • Rule 4(A) multiplies "the adjusted number of points" by a dollar value. Nothing in the rule yields a negative or zero award for an eligible household.

• Effect (2026; a single adult aged 40 in an apartment with a Housing Choice Voucher, heat not in rent, OTHER with a $357 pellet bill). I confirmed each result with a one-off probe at the head:

  County, wages	Head	Rule's pellet row (5)
  Kennebec, $0	6 + 2 + 0 - 9 = -1; -1 × 1.30 = -1.3, rounded up to -1, so -$22	4 × 1.30 = 5.2, rounded up to 6, so $132
  Kennebec, $10,000 (63.90%, rounded to 64%, gives 1.10)	-1.1, rounded up to -1, so -$22	4 × 1.1 = 4.4, rounded up to 5, so $110
  Kennebec, $15,000 (95.85%, rounded to 96%, gives 1.00)	-$22	4 × 1.0 = 4, so $88
  Washington, $10,000	-$22	$110
  Cumberland (3 points), $10,000	0 points, so $0	5 × 1.1 = 5.5, rounded up to 6, so $132
  Unlisted county such as UNKNOWN (0 points; hand-traced)	6 + 0 + 0 - 9 = -3; -3.9, rounded up to -3, so -$66	2 × 1.1 = 2.2, rounded up to 3, so $66

  • Fuels the PR already scored are unaffected. With wood (4), the Kennebec household gets 3 × 1.1 = 3.3, rounded up to 4, so $88.
  • The 2026 rule is unaffected. It has base points and -3, so the same 2027 household gets 8 + 1 + 1 + 0 - 3 = 7; 7 × 1.4 = 9.8, rounded up to 10, so $220. The problem is confined to the 2025-edition parameters: model year 2026 and the unclaimed backfill.

• Severity: should.

  • A regression. At bbdb9b5f78 no eligible household could score below 1 point: the listed-fuel gate held the lowest fuel at wood, 4.
  • Its class. This is the wave's "eligible households/fuels paid $0" class (round-1 S3 was rated the same way), here pushed below zero.
  • Why not critical. The input combination is narrow: a subsidized tenant paying their own heat with an unlisted fuel in a condo, duplex or apartment in a 2- or 3-point county. me_heap feeds no benefit aggregate, so household net income is unchanged. Round 1 offered the 0-point floor without catching this interaction.

• Fix:

  • (a) Preferred. Score OTHER at the lowest row that a fuel reporting OTHER can hold: 5 in the 2025 edition (wood pellets and corn; bio-fuel 6) and 3 in the 2026 rule (biobrick), for example as an other entry in P/points/fuel.yaml.
    • This never pays an OTHER household more than its own fuel's row.
    • It keeps every result positive: in 2025 the lowest score becomes 6 + 0 + 5 - 9 = 2, and in 2026 8 + 1 + 0 + 3 - 3 = 9.
    • T/me_heap.yaml Case 6 would become 9 + 2 + 5 = 16; 16 × 0.7 = 11.2, rounded up to 12, so $264.
  • (b) Otherwise, keep 0 and floor the points (or the benefit) at zero, with a case that pins the floor. This household should then get $0, not -$22. The $0 results for eligible households would remain.
  • Either way:
    • add a 2026 case for a subsidized OTHER apartment in Kennebec;
    • update the value_per_point.yaml minimum comments (the 3-point and $110 minimums);
    • update the body's points table and fuel row;
    • update interpretation 11 and the points and benefit rows of rulespec-us#1898.

Suggestions

G5 (narrowed). Make dated captures of the two rule documents.

• Why. MaineHousing overwrites the rule PDF, which holds the June 29, 2026 rule and is cited for pages 2-17. The Secretary of State's Word copy, cited 23 times for the 2025 edition, will be replaced by filing 2026-134. Neither has a capture that matches the cited edition.
• Fix. A Save Page Now capture of each now, cited beside the live URL, would keep the anchors stable when they are next replaced. This is optional while the content is unchanged.

Verified

Hand-checked new and changed expectations (all period 2026):

• Income Case 6. Child support 2,400 + TANF 10,740 = 13,140, at or under the size-3 limit of 59,504.
  • Downstream: 13,140 / 26,650 = 49.31%, rounded to 49%, gives 1.20; 9 + 5 + 7 + 5 = 26; 26 × 1.2 = 31.2, rounded up to 32, so $704. With TANF excluded it is 9.01%, 1.30 and 34 points, so $748. These match the candidate's example and the body.
• Income Case 10: 6,000.
• Income Case 11: 17,100 + 120 = 17,220. That is at or under 36,836, so the modeled Part B premium is not deducted.
• Income Case 12: 36,537 is below the limit, so the income is 36,836 and the household is eligible.
• me_heap Case 5: 6 + 2 + 0 = 8 (heat in the rent, so no -9); 8 × 0.7 = 5.6, rounded up to 6 points; $21.
• me_heap Case 6: 194.71% rounds to 195%, so 0.7; 11 × 0.7 = 7.7, rounded up to 8 points; $176.
• Eligibility Case 2: OTHER is now true, and the other 11 households are unchanged. Case 3 changed only its comments.
• The author's figures: S1's $462 and $0 (40,000 > 36,836 even after a standard Part B premium), and G3's $572, are correct.
• Case count: 2 + 4 + 3 + 4 + 6 + 1 + 12 + 4 + 12 = 48, as the body says.

Mutation check of the fix commit's new terms. Each would fail a test if removed:

• the TANF term (Income Case 6);
• the (fuel != UNSPECIFIED) part of known_fuel (Case 2 households with bills, and Case 3 household 3);
• the (heat_in_rent & subsidized) exception (Case 3 households 1-2);
• fuel != NONE (Case 3 household 5, NONE with heat in a voucher unit);
• the four new list entries (Case 11).

On main, heating_expense is 0 for UNSPECIFIED and NONE, so these heating-type terms matter only for heat-in-rent households, which Case 3 covers. No case was removed.

Merge resolutions (both blocks correct):

• fpg_limit.yaml takes main's Add North Dakota LIHEAP regular heating assistance #10342 file, and the head's copy is now identical to main's, so the PR adds no federal parameter.
• The programs.yaml coverage line is the base's 31 entries plus ME between MD and MS, with no entry dropped or duplicated. The ME state_implementations entry still sits between MD and MS with verified_years: "2026-2027".
• candidates.yaml merged automatically: the base's 283 entries plus the two ME entries, none removed. The new entries pass test_candidate_fields in CI.

Main-side guards:

• Integrate modeled state unemployment insurance into income flows #9558: the list reads total_unemployment_compensation.
• Count military SBP annuities in state benefit income lists #10317: it reads military_retirement_income.
• Count each Social Security benefit once in Pennsylvania CCW countable income #10408 (still open): Social Security is read once as social_security, and the new railroad_benefits and survivor_benefits are disjoint from it.
• Tie source-conflict markers to the register shared with Axiom #10287 ratchet: main's CONFLICT_COMMENT_RE finds 0 matches in the 202 comment lines of the PR's Maine HEAP files. The guard file has not changed on main since the head's base, so KNOWN_UNMARKED is unaffected.
• Item 17: me_ssp is now counted.
• Item 15: state-gated keys are unchanged and safe.

Sources re-read this round:

• The June 29, 2026 rule (MaineHousing PDF): pp. 12-14, inclusions (a)-(n) and exclusions (a)-(t); and the p. 16 matrix: "Base Points (All eligible households will receive this) 8", with fuels running from Electric 8 to Wood Pellet 4 and Biobrick 3.
• The live HEAP page: the 2026-27 chart, and the accepted fuels, "natural gas, heating oil, kerosene, propane, wood, wood pellets, biobricks, coal, corn, or electricity".
• The Secretary of State's Word copy: still the 2025 edition.
• The Wayback index: the captures named under G5.
• Not opened. I could not open the July 22, 2025 capture that the size-ten candidate cites, because Wayback blocks automated fetches of capture contents. The index lists it as a 371,473-byte PDF from before the 2026 rule. Either way, the candidate's reading rests on the 2025 edition's 70% row ("not exceeding the maximum of the greater of 150% FPIG or 60% state median income"), which round 1 verified in the Word copy.

Main's 8 newer commits touch none of Maine HEAP's dependencies. They are AK HAP, the Maine childless EITC, the self-employed health insurance deduction, the ss_aime change and a contributed SECA reform.

Axiom

Valid at this head: axiom: TheAxiomFoundation/rulespec-us#1898 queued.

• State: OPEN and labelled pe-parity.
• It describes this head. It was updated 2026-10-29 13:44 UTC, names head cc78d48246 (fix commit 7d4e4569a0, merge base c55b806541) and is dispatch-ready.
  • The countable-income row lists the 5 earned and 21 unearned sources plus tanf once.
  • The eligibility row has the new known_fuel rule.
  • Interpretation 11 records OTHER at 0 fuel points as a floor.
  • Companion test 9 is the $176 OTHER household.
• The N1 fix will change interpretation 11, the points and benefit rows, and test 9 (or add a subsidized OTHER companion case), so the issue needs a refresh when it lands.

CI

35 pass, 0 failed, 0 pending. I re-checked gh pr checks 10437 at the end of this review.

• The run. Run 40792595326 tested head cc78d48246 (pull_request, created 2026-10-29 00:13 UTC). It includes main through c55b806541, after Tie source-conflict markers to the register shared with Axiom #10287, Count military SBP annuities in state benefit income lists #10317 and the core fix for test_social_security_input_state_machine.
• Maine tests. In States-shard-3, batch 6/13 (states/me), all 9 Maine HEAP files passed: 2 + 4 + 3 + 4 + 6 + 1 + 12 + 4 + 12 = 48.
• Guards. Rest shard 3 ran test_source_conflicts.py, test_unemployment_compensation_readers.py and test_members_are_state_gated, and passed.
• Also passing: Microsimulation, Household API Partners and every other baseline and contrib shard.
• Known main-caused failures: none apply.
• Locally: I ran no test files, only one small probe at the head to confirm the N1 figures.

Branch

• Position: 4 commits ahead of main (1976c4b600) and 8 behind.
• Merge: conflicts. git merge-tree --write-tree PolicyEngine/main cc78d48246 exits 1 with two content conflicts (branch note):
  • policyengine_us/programs.yaml, the LIHEAP coverage line. AK Add Alaska LIHEAP regular heating assistance #10341 merged and added AK. The resolution is AK, AR, AL, AZ, DC, GA, Riverside County, MA, FL, IL, IA, IN, KS, KY, MD, ME, MS, NC, ND, NE, NH, NJ, NY, OH, OK, OR, SD, RI, TX, UT, VA, WA, WY, which keeps AK and ME and drops nothing.
  • source_conflicts/candidates.yaml. Extend Maine's childless EITC expansion to 2021 students aged 19 to 23 #10526 added us-me:childless-eitc-age-cap at the same position. Keep both blocks.
• Siblings. The 10 open LIHEAP siblings each edit the same coverage line and will need a one-line resolution: PA Add Pennsylvania LIHEAP regular heating assistance #9971, LA Add Louisiana LIHEAP regular heating assistance #10429, TN Add Tennessee LIHEAP regular energy assistance #10430, NM Add New Mexico LIHEAP regular heating assistance #10431, NV Add Nevada Energy Assistance Program Fixed Annual Credit #10432, MN Add Minnesota EAP Primary Heat benefit #10433, WI Add Wisconsin WHEAP regular heating benefit #10434, MT Add Montana LIHEAP regular heating assistance #10435, VT Add Vermont Seasonal Fuel Assistance #10436 and MO Add Missouri LIHEAP Energy Assistance #10438.

0 critical, 1 should and 1 suggestion are open at this head.

Verdict: REQUEST_CHANGES

[DTrim99]

Requesting changes, round 2: 0 critical, 1 should. All four round-1 shoulds are fixed and pinned. New (from the S3 fix): OTHER scores 0 fuel points, so under the 2025 edition a subsidized apartment tenant paying a pellet bill in Kennebec is paid -$22 (the rule's pellet row gives $110). Score OTHER at the lowest unlisted-fuel row (5 in 2025, 3 in 2026), or floor at zero with a pinning case. Full report in the comment above.