Implement the New York Child Care Assistance Program under gov/states/ny

[hua7450]

Summary

Implements New York's Child Care Assistance Program (CCAP) as a proper state program under gov/states/ny/ocfs/ccap/, encoding current law only — the October 2024 market rates and the post-October-2023 policy structure.

Closes #9282

The legacy "federal" CCDF implementation under gov/hhs/ccdf/ (which is actually New York data, and is inert on main — not registered in any benefit aggregate) is left untouched here; its removal is a follow-up tracked in #9283.

Regulatory authority

• 18 NYCRR Part 415 (Child Care Services) and Part 404 (Eligibility)
• Social Services Law §§ 410-u, 410-w, 410-x as revised effective October 1, 2023
• 24-OCFS-LCM-22 (October 2024 market rates), 23-OCFS-ADM-18, 22-OCFS-ADM-18
• NYS Register, May 1, 2024, Rule Making Activities (OCFS)

What is modeled

Component	Rule	How modeled
Income limit	85% of state median income, the sole ceiling since 2023-10-01 (SSL 410-w)	ny_ccap_income_eligible
Countable income	18 NYCRR 404.5(b)(5); a child's SSI excluded, an adult's counted	ny_ccap_countable_income (8 sources)
Eligible child	Federal age/asset tests + NY categorical routes: foster care and protective/preventive services eligible without regard to income; homelessness waives the activity test only	ny_ccap_eligible_child
Family share	1% of income above the state income standard, $1 weekly minimum, categorical exemptions (public assistance, homeless, foster care, protective services)	ny_ccap_family_share, ny_ccap_family_share_exempt
Market rates	Oct 2024 schedule: 4 county groups × 5 provider types × 4 age groups × weekly/daily/part-day, excess-day pricing under 415.9(b)	ny_ccap_market_rate + rates/*.yaml
Benefit	Per-child cap at min(expense share, market rate), less the family share	ny_ccap

All 240 current rate cells were verified against 24-OCFS-LCM-22 Attachment A.

Not modeled (by design)

• Historical eras (pre-Oct-2024 rates, the 200%/300% FPG income limits, the 10% family share) — current law backdates via backdate_parameters
• Non-traditional-hours/homelessness/accreditation payment differentials, special-needs substituted rates, excess-period payments, Title XX levels, the child-only family-share exception, waitlist rationing (all listed in programs.yaml notes)
• Provider county (household county proxies; unknown counties default to the lowest-rate group)

Registration

• gov/hhs/ccdf/child_care_subsidy_programs.yaml (all blocks) → flows into child_care_subsidies
• gov/household/household_state_benefits.yaml (all eras)
• programs.yaml CCDF state_implementations

Test plan

• 68 NY CCAP YAML tests pass (unit tests per variable + integration cases asserting the federal aggregator)
• 63 federal CCDF YAML tests pass (files restored to main's state)
• test_aggregate_list_integrity.py 15/15
• CI passes

🤖 Generated with Claude Code

[codecov]

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 100.00%. Comparing base (0eec199) to head (3ad18f4).
⚠️ Report is 9 commits behind head on main.

Additional details and impacted files

@@            Coverage Diff             @@
##              main     #9187    +/-   ##
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  Coverage   100.00%   100.00%            
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  Files            2        12    +10     
  Lines           31       204   +173     
  Branches         0         5     +5     
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+ Hits            31       204   +173     

Flag	Coverage Δ
unittests	100.00% <100.00%> (ø)

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[PavelMakarchuk]

PR Review

Reviewed head 7439bb7 — 17 parameter files, 15 variables, 117 YAML tests, programs.yaml entry, aggregator registration — against 18 NYCRR Part 415, SSL § 410-w, 24-OCFS-LCM-22 (Oct 2024 market rates) and 23-OCFS-ADM-18. Structure mirrors the other state CCAPs (NC/CO/SC: SPM-unit monthly benefit = min(expenses, rate) − family share; duration enum from childcare_hours_per_day / days_per_week; defined_for = StateCode.NY; ny_child_care_subsidies aggregator) and the legacy inert gov/hhs/ccdf NY data is left for #9283.

Caveat: ocfs.ny.gov was unreachable from the review sandbox, so individual rate cells in rates/*.yaml were not re-checked against Attachment A; the assessment of values relies on the PR's page-anchored citations.

🔴 Critical (Must Fix)

None.

🟡 Should Address

1. 12-hour rule: reference says "12 hours or more", code applies "> 12". parameters/gov/states/ny/ocfs/ccap/duration/daily_maximum_hours.yaml:9 titles its reference "care of 12 hours or more in a day earns an additional market rate", but variables/.../rates/ny_ccap_market_rate.py:56-63 computes excess_hours = max_(hours - 12, 0) and adds a period only when excess_hours > 0. Tests (ny_ccap_duration_of_care.yaml Cases 10/11, ny_ccap_market_rate.yaml Case 8) only exercise > 12. Reconcile with 415.9 / LCM §III.4.b — either hours >= daily_maximum_hours or fix the reference wording — and add an exactly-12-hours test either way.
2. Hourly rate tier is absent. OCFS Attachment A (and the legacy gov/hhs/ccdf/amount.yaml NY schedule) publish an HOURLY column; the PR encodes weekly/daily/part-day only, and ny_ccap_duration_of_care.py maps everything under 6 h/day to part-day. Under 415.9 short care (fewer than 3 hours/day) is priced hourly. Either add the hourly tier or list it explicitly under "not modeled" in the programs.yaml notes (currently not mentioned).

🟢 Suggestions

1. Start dates vs cited instruments. age_groups.yaml and duration/*.yaml start 2019-05-01, eligibility/age_limit/*.yaml start 2021-10-01, while the only cited sources are the 2024 LCM / current Part 415. Backfilling makes this harmless, but align the dates with the cited instrument (or cite the 2019 LCM) for consistency with rates/*.yaml and county_group.yaml (2024-10-01).
2. parameters/gov/hhs/ccdf/child_care_subsidy_programs.yaml:98,150 — ny_child_care_subsidies is appended at the end of the 2024/2025 blocks but placed alphabetically in the 2021 block; pick one ordering.
3. ny_ccap.py:20-22 gates the benefit on childcare_hours_per_day > 0 (also drives duration/rate). A user entering only expenses gets $0 — same as SC/GA, unlike CO/NC; worth a line in the programs.yaml notes.
4. ny_ccap_county_group.py:33 — default GROUP_3 (lowest rates) for unimputed counties is documented; since NYC + downstate hold most children, the downward microsim bias is worth one more sentence in the notes.
5. Branch/changelog are named ny-ccdf while everything else is ny_ccap_* — cosmetic.

---

Validation Summary

Check	Result
Regulatory Accuracy	2 issues (12-hour boundary; hourly tier). 85% SMI limit, 1% share above FPL with $1/week minimum (415.3(e)(3)-(4), 23-OCFS-ADM-18 eff. 2023-10-01), age 13 / 18 / 19, 4 county groups × 5 provider types × 4 age bands, weekly ≥30h/5d, daily ≥6h — structure verified against the cited rules
Reference Quality	0 issues — sampled 10 parameter files; all have titled references with page anchors (ADM/LCM pages, NYCRR pages, SSL, 45 CFR 98.20, CCDF State Plan p.91)
Code Patterns	0 issues — no hard-codes; ny_ccap_* naming; add()/adds correct; YEAR bools read via period.this_year from MONTH formulas; vectorized select/where/np.isin; programs.yaml entry present; registered in all blocks of child_care_subsidy_programs.yaml and household_state_benefits.yaml; changelog added correct; no partner-test edits needed (partner shard green)
Test Coverage	0 blocking gaps — 85% SMI at/above/below, copay at FPL / just above / minimum crossover, per-child cap and ineligible sibling, all four county groups and provider types, child_care_subsidies aggregation. Missing: exactly-12-hour case (see #1)
CI Status	Partner + codecov green; full-suite shards were still pending at review time

Verdict: COMMENT — approve once the 12-hour boundary is reconciled and the hourly tier is either added or documented as out of scope.

[hua7450]

Thanks — addressed in 2372ff7:

Should address

1. 12-hour boundary — switched to the literal LCM reading: ny_ccap_market_rate now adds the extra period on each day of care at or above 12 hours (>=), priced by the time over 12 hours, so exactly-12 draws a part-day period. Added ny_ccap_market_rate.yaml Case 8a (12 h × 5 d → weekly + 5 part-day) and 8b (11.99 h → weekly only); parameter description, variable docs, programs.yaml notes and changelog aligned.
2. Hourly tier — no longer exists in current law. 24-OCFS-LCM-22 Attachment A (pp. 15–18) publishes only Weekly / Daily / Part-Day rows for every provider type and county group, and 18 NYCRR 415.9(a)–(c) (compilation current as of 12/24/2025) defines only those three tiers — the word "hourly" appears in neither document. The HOURLY column lives only in the legacy 2019 schedule (gov/hhs/ccdf/amount.yaml, cited to the 2019 market-rate survey), which Remove the inert federal CCDF implementation (New York data under gov/hhs/ccdf) #9283 will retire. Added a sentence to the programs.yaml notes so it isn't re-raised.

Suggestions

• 3 & 4 — added to programs.yaml notes: the benefit needs childcare_hours_per_day / childcare_days_per_week (the rate is priced by duration; expenses alone yield $0), and the group-3 default is the lowest-rate group while NYC/downstate hold most of the state's children.
• 1 (parameter start dates) — inert under backdate_parameters; left as-is.
• 2 (ordering in child_care_subsidy_programs.yaml) — the 2024/2025 blocks are append-ordered (WY, TX at the end), so NY follows that; the 2021 block is alphabetical and NY sits alphabetically there.
• 5 — cosmetic, left.

Also in 5997301: added ny_ccap_activity_eligible.yaml (9 cases — the work-hours, two-caretaker, student, public-assistance and fallback branches had no direct coverage), fixed a doc claim in ny_ccap_family_share_exempt (415.3(e)(1) does list the ≤100%-SIS exception; page anchor → 19), and corrected the 415.2(a)(2) citations to (v)(a)/(v)(d). 119 NY YAML tests pass locally.