Part of #9330 (disconnected disability inputs audit).
Summary
The three state working-disabled Medicaid buy-in implementations answer the same federal question three different ways. MS is wired correctly; CA WDP and IL HBWD are missing the definitional flag the federal group requires; and IL additionally treats an eligible worker as a non-disabled spouse in its income calculation.
Legal standard
42 USC 1396a(a)(10)(A)(ii)(XIII): individuals "who but for earnings in excess of the limit established under section 1396d(q)(2)(B), would be considered to be receiving supplemental security income" — SSI §1614 disability without the earnings/SGA screen. The exact model input is meets_ssi_disability_criteria (not is_ssi_disabled, which applies the SGA screen the buy-in exists to waive).
For IL specifically, 89 Ill. Adm. Code 120.314: "To be eligible for medical assistance as a disabled person an individual must be determined disabled as currently defined by the Social Security Administration" (citing 20 CFR 416 Subpart I). The HBWD file's own comment notes SGA/earned-income rules don't apply.
Defect A — CA and IL missing meets_ssi_disability_criteria
policyengine_us/variables/gov/states/ca/chhs/wdp/eligibility/ca_wdp_disability_eligible.py:12policyengine_us/variables/gov/states/il/hfs/hbwd/eligibility/il_hbwd_disability_eligible.py:15
Both: is_disabled | is_blind | (social_security_disability > 0). Wrongly excluded: SSI-criteria-flagged workers with is_disabled = False — the program's core population (workers above SGA whose only disability flag is the SSI medical criteria).
MS (ms_wd_disability_eligible.py) is the correct template: meets_ssi_disability_criteria | is_blind | (ssdi > 0).
Fix: add meets_ssi_disability_criteria to CA and IL.
Defect B — IL worker test narrower than its own eligibility test
policyengine_us/variables/gov/states/il/hfs/hbwd/income/earned/il_hbwd_countable_earned_income.py:24:
is_hbwd_worker = is_disabled | is_blind
An SSDI-receipt-only worker passes il_hbwd_disability_eligible but is then treated as a non-disabled spouse — own earnings counted at gross with no §120.510(i)/§120.362 earned-income exemptions.
Fix: derive the worker flag from il_hbwd_disability_eligible (also inherits fix A).
Side note
is_working_disabled_buy_in_for_medicaid (the aggregator) mixes periods — CA at YEAR, IL/MS at first_month — worth normalizing while in there.
Part of #9330 (disconnected disability inputs audit).
Summary
The three state working-disabled Medicaid buy-in implementations answer the same federal question three different ways. MS is wired correctly; CA WDP and IL HBWD are missing the definitional flag the federal group requires; and IL additionally treats an eligible worker as a non-disabled spouse in its income calculation.
Legal standard
42 USC 1396a(a)(10)(A)(ii)(XIII): individuals "who but for earnings in excess of the limit established under section 1396d(q)(2)(B), would be considered to be receiving supplemental security income" — SSI §1614 disability without the earnings/SGA screen. The exact model input is
meets_ssi_disability_criteria(notis_ssi_disabled, which applies the SGA screen the buy-in exists to waive).For IL specifically, 89 Ill. Adm. Code 120.314: "To be eligible for medical assistance as a disabled person an individual must be determined disabled as currently defined by the Social Security Administration" (citing 20 CFR 416 Subpart I). The HBWD file's own comment notes SGA/earned-income rules don't apply.
Defect A — CA and IL missing
meets_ssi_disability_criteriapolicyengine_us/variables/gov/states/ca/chhs/wdp/eligibility/ca_wdp_disability_eligible.py:12policyengine_us/variables/gov/states/il/hfs/hbwd/eligibility/il_hbwd_disability_eligible.py:15Both:
is_disabled | is_blind | (social_security_disability > 0). Wrongly excluded: SSI-criteria-flagged workers withis_disabled = False— the program's core population (workers above SGA whose only disability flag is the SSI medical criteria).MS (
ms_wd_disability_eligible.py) is the correct template:meets_ssi_disability_criteria | is_blind | (ssdi > 0).Fix: add
meets_ssi_disability_criteriato CA and IL.Defect B — IL worker test narrower than its own eligibility test
policyengine_us/variables/gov/states/il/hfs/hbwd/income/earned/il_hbwd_countable_earned_income.py:24:An SSDI-receipt-only worker passes
il_hbwd_disability_eligiblebut is then treated as a non-disabled spouse — own earnings counted at gross with no §120.510(i)/§120.362 earned-income exemptions.Fix: derive the worker flag from
il_hbwd_disability_eligible(also inherits fix A).Side note
is_working_disabled_buy_in_for_medicaid(the aggregator) mixes periods — CA at YEAR, IL/MS atfirst_month— worth normalizing while in there.