Implement Minnesota Child Care Assistance Program (CCAP)

[hua7450]

Summary

Implements Minnesota's Child Care Assistance Program (CCAP) in PolicyEngine — a provider-rate reimbursement subsidy computed per child as the lesser of the provider's charge or the state maximum rate, minus the biweekly parent fee. Administered by the Minnesota Department of Children, Youth, and Families (DCYF), which took CCAP over from the Department of Human Services (DHS) in 2024.

Closes #8636

Regulatory Authority

• Minn. Stat. ch. 142E (Child Care Programs) — renumbered from ch. 119B during the 2025 DHS→DCYF transition (cite 142E for current law, 119B for historical):
  • 142E.15 Parent fee (copayment): https://www.revisor.mn.gov/statutes/cite/142E.15
  • 142E.17 Child care rates (incl. subd. 1(f) day/week payment caps, subd. 2(b) legal non-licensed caps): https://www.revisor.mn.gov/statutes/cite/142E.17
• Minn. Rules ch. 3400 (Child Care Fund): https://www.revisor.mn.gov/rules/3400/full
  • 3400.0170 Income eligibility (counted income, allowable deductions): https://www.revisor.mn.gov/rules/3400.0170/
• Minn. Stat. ch. 256P (income methodology): 256P.06 what income is/isn't counted — https://www.revisor.mn.gov/statutes/cite/256P.06
• DHS CCAP Policy Manual (issued Aug 2025): §4.6 authorized activities, §6.3 income limits, §6.6/§6.6.1 counted & exempt income, §6.18 allowable deductions, §9.9 rate-unit determination & payment caps, §9.24.9/§9.24.12 quality differentials.
• Operational schedules (hosted at DHS edocs):
  • DHS-6441F Standard Maximum Rates (eff. 01/06/2025): https://edocs.dhs.state.mn.us/lfserver/Public/DHS-6441F-ENG#page=6
  • DHS-6413N Copayment / parent-fee schedule (eff. 10/13/2025, FFY2026 SMI): https://edocs.dhs.state.mn.us/lfserver/Public/DHS-6413N-ENG#page=6
  • DHS-6443D Registration fees (eff. 01/06/2025): https://edocs.dhs.state.mn.us/lfserver/Public/DHS-6443D-ENG#page=5

Program Overview

• Three subprograms, all sharing the same benefit/rate/copay mechanics and differing only in entry income limit and funding: MFIP/DWP Child Care (67% SMI entry), Transition Year (families who left MFIP within the prior year), and Basic Sliding Fee (47% SMI entry). Modeled via a single income-limit switch rather than separate benefit formulas.
• Income limits are defined as a percentage of State Median Income by household size. These reconcile exactly with the federal hhs_smi variable × {47% / 67% / 85%} (verified to the dollar against DHS-6413N: 2-person 47% = $46,022; 3-person 67% = $81,042; 4-person 85% = $122,398), so the implementation reuses hhs_smi rather than introducing a separate Minnesota SMI variable.

Eligibility

Requirement	Source	How Modeled
Family has ≥1 eligible child in care	Minn. Rules 3400.0110; manual §6.x	mn_ccap_eligible aggregates mn_ccap_eligible_child over the SPM unit
Child under 13 (under 15 if disabled)	Minn. Stat. 142E.01/142E.11	age_threshold/child.yaml (13) + disabled_child.yaml (15) in mn_ccap_eligible_child
Child is a dependent	program rules	is_tax_unit_dependent in mn_ccap_eligible_child
Child is a citizen / qualified noncitizen	45 CFR 98.20; 8 USC 1641	reuse federal is_ccdf_immigration_eligible_child
Parent(s) in an authorized activity	manual §4.6.1/§4.6.3; Minn. Stat. 142E.12	mn_ccap_activity_eligible (see below)
Family assets ≤ $1,000,000	manual §4.12; Minn. Rules 3400.0170	reuse federal is_ccdf_asset_eligible
Income test (% of SMI)	manual §6.3; DHS-6413N p.5	mn_ccap_income_eligible (SMI test reusing hhs_smi)

Authorized activity (mn_ccap_activity_eligible; manual §4.6.1, §4.6.3; Minn. Stat. 142E.12 subd. 1(b)): at least one caretaker must be in an authorized activity — employed an average of ≥ 20 hrs/week, or enrolled as a full-time student (education is itself an authorized activity under §4.6.6.9, with no work-hours floor). In a two-caretaker family the other caretaker must also be active or "unable to provide care" — modeled via is_disabled, is_incapable_of_self_care, is_incarcerated (house arrest), and out-of-home/residential care-facility status. MFIP/DWP families meet the requirement categorically through their Employment Plan (is_tanf_enrolled), and families experiencing homelessness are exempt from the activity requirement (§4.6.9), modeled via is_homeless — we don't track the manual's ~3-month exemption window, so the exemption applies for the full period. The meets_ccdf_activity_test input covers approved activities we don't derive directly (job search, education/training programs, temporary leave) and the applicable-minimum-wage component.

Income

Income base = annual gross income after allowable deductions, used for both the eligibility test and the copay band lookup (manual §6.3, §6.6; Minn. Rules 3400.0170 subp. 4; Minn. Stat. 256P.06).

• Counted earned income (gross, before payroll deductions) — wages/salary incl. overtime and bonuses, paid vacation/sick leave, tips, commissions, severance, royalties, honoraria, taxable allowances, incentive payments, military pay (combat-zone pay excluded). Parameter: income/countable_income/earned.yaml.
• Self-employment is counted separately and floored per person (income/countable_income/self_employment_sources.yaml): a net business loss may offset other self-employment income but cannot reduce wages or unearned income (Minn. Rules 3400.0170 subp. 4; manual §6.15.6), so mn_ccap_gross_earned_income applies max_(self_employment, 0) per person before adding it to wages.
• A child's earned income is excluded (manual §6.6.1 / Exempt Earned Income chart §16.27): mn_ccap_gross_earned_income subtracts the earnings of household members under 18 (is_child). This is a simplification — the manual additionally counts a non-student minor's earnings and a dependent post-secondary student's earnings, which we don't separately track.
• Counted unearned income (exhaustive "includes only" list) — cash assistance (MFIP cash, MFIP Housing Assistance Grant, DWP, MSA, GA, RCA), interest/dividends, capital gains on real property, contract-for-deed above principal+interest, trust income (excl. special/supplemental needs trusts), family-loan interest, unemployment insurance, disability insurance, workers' comp, retirement/pension/veteran benefits, child/spousal support not assigned to the state, RSDI gross, cash prizes/winnings, taxable military entitlements. Parameter: income/countable_income/unearned.yaml. Income types without a PolicyEngine variable are listed as inline comments.
• Allowable deductions (manual §6.18, verified; Minn. Rules 3400.0170 subp. 6a): child support paid out-of-household; spousal support paid out-of-household; medical/dental/vision insurance premiums paid by family members; the un-reimbursed portion of an insurance premium for Medical Assistance recipients; expenditures necessary to secure payment of unearned income. Parameter: income/deductions/sources.yaml; applied as mn_ccap_countable_income = max_(gross − deductions, 0).

Benefit Calculation

Per eligible child:

subsidy = max_(min_(actual_expenses, max_rate × (1 + quality_differential)) − biweekly_copay, 0)

summed across eligible children. Actual expenses come from the federal spm_unit_pre_subsidy_childcare_expenses (RI/MA/CO precedent). The parent pays any provider charge above the maximum, plus the copay (manual §9.9; Minn. Stat. 142E.17 subd. 1(e),(i)).

• Maximum rate keyed by County (87 counties) × provider type (Family Child Care | Child Care Center) × age group (Infant | Toddler | PreSchool | School Age) × rate unit. License-exempt programs are paid at the licensed-center rate for the same age group; LNL (Legal Non-Licensed) providers use their own hourly column. Parameters: rates/{weekly,full_day,hourly,lnl_hourly}.yaml.
• Rate unit (§9.9, single provider): weekly if scheduled/authorized > 35 hrs/week; full-day if ≤ 35 hrs/week and > 5 hrs/day; hourly if ≤ 35 hrs/week and ≤ 5 hrs/day. LNL providers are forced to hourly. Variable: mn_ccap_rate_unit; parameters: rate_unit/{weekly,daily}_hours_threshold.yaml.
• Monthly conversion & statutory caps (Minn. Stat. 142E.17 subd. 1(f), 2(b); manual §9.9): weekly max × (weeks/12); daily and hourly billing are converted to a monthly maximum subject to the statutory ceilings — payment for one day of care cannot exceed the daily rate, payment for one week cannot exceed the weekly rate, and legal non-licensed payment is capped at 10 hours/day and 50 hours/week. Parameters: rates/lnl_max_daily_hours.yaml (10), rates/lnl_max_weekly_hours.yaml (50).
• Quality differential applied as a multiplier on the standard maximum rate, capped at the provider's charge: ×1.15 for accredited/credentialed or 3-star Parent Aware providers, ×1.20 for 4-star Parent Aware (manual §9.24.9/§9.24.12; Minn. Stat. 142E.17 subd. 4–5). Parameter: quality_differential.yaml.
• Copay (parent fee) looked up by household size (2–13) × annual-income band → flat biweekly dollar amount, then converted to monthly (DHS-6413N pp.6–11; Minn. Stat. 142E.15). $0 in the lowest band, rising with income. Parameters: copay/biweekly/size_2.yaml … size_13.yaml; variable: mn_ccap_copay.

Source Verification

Every published dollar value was verified against the official PDFs:

• DHS-6441F provider rates — all county × provider-type × age × rate-unit values (incl. LNL) checked against the form; full match.
• DHS-6413N copay schedule — all 12 household-size schedules × income bands checked; full match. Entrance/exit dollar levels reconcile to hhs_smi × {47% / 67% / 85%}.
• Aug 2025 CCAP Policy Manual — eligibility, activity (§4.6), income counting (§6.6/§6.6.1), deductions (§6.18), rate-unit logic and payment caps (§9.9), and quality differentials (§9.24) verified against the implementation.

Not Modeled

What	Source	Why excluded
Child-support cooperation requirement	manual §4.9	Behavioral/administrative status we don't track
Transition Year continuous-eligibility history (67% vs 47% entry)	manual §6.3	We don't track prior CCAP eligibility history; defaults to the applicable static limit
Redetermination 67%-of-SMI exit limit	manual §6.3	Point-in-time model — we don't track the 12-month redetermination clock
Non-caregiver adult / "CCAP family" scoping	manual ch. 5, §6.6.1	Income is summed over the SPM unit; a co-resident non-dependent adult's income may be counted where the manual would exclude it
120-hour/child/biweekly payment cap	manual §9.9	Deferred; the per-day and per-week rate caps (subd. 1(f), 2(b)) are now applied, but the 120-hour aggregate cap is not
Registration-fee county-max cap + max 2 fees/child/12 mo	manual §9.3.6; DHS-6443D	Deferred — the optional input ships now; the county-max table is pending
St. Cloud / Sartell city rate tier	DHS-6441F	Providers in those two cities use the surrounding county rate (only St. Cloud family-child-care rates differ materially)
Copay cannot increase mid 12-month eligibility period; copay waived by provider/third party	manual §6.21	Point-in-time; we don't track the eligibility clock or third-party copay payment
BSF capped allocation → waiting list	DHS-4745	We don't model program-capacity waitlists

Verification TODO

• Confirm the quality differential as a flat ×1.15 / ×1.20 multiplier is acceptable vs transcribing the separate quality-differential rate tables (v1 uses the multiplier per scope decision).
• CI passes.

Files

policyengine_us/parameters/gov/states/mn/dcyf/ccap/   (32 params)
  age_group/{center_months,family_months}.yaml
  age_threshold/{child,disabled_child}.yaml
  activity/min_weekly_hours.yaml
  copay/biweekly/size_2.yaml … size_13.yaml
  income/countable_income/{earned,unearned}.yaml
  income/deductions/sources.yaml
  income/smi_rate/{entrance_mfip,entrance_other,exit_during_period}.yaml
  quality_differential.yaml
  rate_unit/{weekly,daily}_hours_threshold.yaml
  rates/{weekly,full_day,hourly,lnl_hourly}.yaml
  rates/{lnl_max_daily_hours,lnl_max_weekly_hours}.yaml

policyengine_us/variables/gov/states/mn/dcyf/ccap/   (19 variables)
  mn_ccap.py, mn_child_care_subsidies.py, mn_ccap_countable_income.py,
  mn_ccap_gross_earned_income.py, mn_ccap_gross_unearned_income.py,
  mn_ccap_income_deductions.py, mn_ccap_max_rate.py, mn_ccap_provider_rate.py,
  mn_ccap_provider_type.py, mn_ccap_quality_rating.py, mn_ccap_rate_unit.py,
  mn_ccap_age_group.py, mn_ccap_enrolled.py, mn_ccap_registration_fee.py,
  copay/mn_ccap_copay.py,
  eligibility/{mn_ccap_eligible,mn_ccap_eligible_child,mn_ccap_income_eligible,mn_ccap_activity_eligible}.py

policyengine_us/tests/policy/baseline/gov/states/mn/dcyf/ccap/   (12 test files)
  integration.yaml, mn_ccap_age_group.yaml, mn_ccap_copay.yaml,
  mn_ccap_countable_income.yaml, mn_ccap_max_rate.yaml, mn_ccap_provider_rate.yaml,
  mn_ccap_rate_unit.yaml, mn_child_care_subsidies.yaml,
  eligibility/{mn_ccap_eligible,mn_ccap_eligible_child,mn_ccap_income_eligible,mn_ccap_activity_eligible}.yaml

Test plan

• 107 MN CCAP tests pass locally (policyengine-core test)
• CI passes

[codecov]

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 100.00%. Comparing base (e0c18f7) to head (90fbe7a).
⚠️ Report is 2 commits behind head on main.

Additional details and impacted files

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+ Hits           292       308   +16     

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[PavelMakarchuk]

Program Review — Minnesota Child Care Assistance Program (CCAP)

Automated multi-agent review (regulatory, references, code patterns, test coverage, and source-value audits of income/copay + the 87-county provider-rate tables).

Excellent, thorough implementation of a large, complex program — 113 CCAP + 11 param/system tests pass, vectorized clean, and every audited value matches source: SMI rates 0.47/0.67/0.85 (DHS-6413N), income limits reconstruct the at-a-glance table to <$1, the biweekly copay schedule matches DHS-6413N bracket-by-bracket, and all provider rate cells match DHS-6441F exactly (8 counties × 2 types × 4 ages × 4 units, largest diff 0.00). The 67/47/85 three-way SMI split is verbatim-correct per 142E.10, and the Parent Aware 15%/20% differential checks out. Requesting changes on a few items — none are value errors.

✅ Cleared (not an error) — flagging so it isn't "fixed"

rate_unit/weekly_hours_threshold = 35 (and daily_hours_threshold = 5) are correct. These implement the Policy Manual §9.9 rate-UNIT billing rule (>35 hr/wk → weekly; ≤35 & >5/day → daily; else hourly). Statute 142E.17 subd 6's "30 hours" is a different rule — the eligibility floor to access the weekly rate basis — not the billing threshold. Please do not change 35 → 30.

Should address

1. Revert the unrelated uv.lock change. This PR bumps policyengine-us 1.721.1 → 1.729.5, which is unrelated to CCAP — git checkout main -- uv.lock.
2. Rate-unit citation quality (rate_unit/weekly_hours_threshold.yaml, daily_hours_threshold.yaml). The values are right, but they cite a non-resolving Policy Manual §9.9 dynamic-conversion link (and 142E.17 subd 1, which sets no hour threshold). Please supply a resolvable §9.9 anchor and add a one-line comment distinguishing the statutory 30-hr eligibility floor from the §9.9 35-hr billing rule (so a future updater doesn't "correct" it to 30).
3. Test coverage gaps: add an explicit out-of-state (non-MN) county case to exercise the mn_ccap_provider_rate masking guard; broaden county coverage beyond Becker + Hennepin; and add a disabled 13–14-year-old end-to-end through a benefit.

Suggestions

• Note the copay date back-extrapolation (rates eff 2025-01-06, copay eff 2025-10-13 → Jan–Sep 2025 back-fills the Oct copay schedule; verified non-zero — worth a one-line comment).
• quality_differential.yaml: STAR_4: 0.20 → 0.2 (value-formatting rule).
• Add a comment in lnl_hourly.yaml that the DHS-6441F LNL column already reflects the 90%-of-licensed rule (so it isn't recomputed as a literal 90%).
• Note that DWP is folded into the is_tanf_enrolled MFIP proxy.
• DHS-6441F lists St. Cloud/Sartell as separate city rate blocks; the PR keys by county only (St. Cloud city FCC rates differ from Stearns county) — a documented sub-county simplification worth a note.

Cleared / verified

All source values match; 67/47/85 split correct; Parent Aware differential correct; all 87 county enums present (no orphans); no reinvented variables; no shared federal code touched; programs.yaml: complete justified.

🤖 Multi-agent review via /review-program