[hua7450]

Closes #10357
Closes #10358

What and why

PolicyEngine's medically needy pathway for aged, blind and disabled people (is_medically_needy_for_medicaid) had two problems. Five states that run the pathway had it switched off, and most limits still held 2018 values. This PR switches the five states on and updates the limits in 14 states. Where a state ties its limit to the poverty guideline or the SSI federal benefit rate, the PR encodes that rate in place of a dollar amount.

Pathway switched on (senior and disabled flags)

State	Limits (monthly income; assets)	Source
AR	$108.33 / $216.66 (was $108 / $217); $2,000 / $3,000 (unchanged)	AR DHS Quick Reference ("AABD Adult Spend Down $108.33 $216.66"); Medical Services Policy Manual (9/2026), O-710, p435 ($108.33 / $216.66)
IA	$483 / $483; $10,000 (unchanged)	Iowa Admin. Code 441-75.8, pp. 20 ("SSI-related persons"), 22 (resources, $10,000 per household), 24 (MNIL $483 / $483)
NJ	$367 / $434; $4,000 / $6,000 (unchanged)	DMAHS Medically Needy fact sheet (archived 2026-05-14; the live link now returns 404)
IL	100% FPL; $17,500 from 2023-05-12	305 ILCS 5/5-2(2)(a)(ii) (income after medical costs "equal to or less than 100% of the federal poverty level"); PM 15-06-02-a ("The Community Standard is 100% of the Federal Poverty Level"); PM 15-08-00; PM 07-02-01 ("Effective 05/12/2023, the asset limit for Medical cases is $17,500")
ND	83% FPL, then 90% FPL from 2024-01-01; $3,000 / $6,000 (unchanged)	Manual 510-05-85-40 ("equal to 90% of the poverty level"); ML 3702 (83% in April 2023); SPA ND-23-0034 (effective 1/1/2024); NDAC 75-02-02.1-26

Pathway switched off (senior and disabled flags)

AZ, ID, IN, NM and NV had the senior and disabled flags on, swapped with AR, IL, IA, NJ and ND. KFF's 2018 and 2026 tables, already cited in the flag files, list no medically needy program for aged, blind or disabled people in these five states. They are now off from 2015. Their limits were -.inf, so no result changes.

Limits tied to a federal amount

State	Before	After	Source
KS	$475 / $475	SSI rate from 2025-07-01 ($994 / $1,491 in 2026)	CMS approval of KS-25-0019, p7 ($475 for one and two people), p2 (effective July 1, 2025) and p46 (disregards the difference between the MNIL and the SSI federal benefit rate); KEESM F-8 (01-26): independent living $994 (1) / $1,491 (2)
WA	$750 / $750	One-person SSI rate for one and two people	WAC 182-519-0050(5) ("the one-person federal benefit rate (FBR) ... or the MNIL listed in the chart below, whichever amount is higher"); in force since WSR 12-20-001
MN	$810 / $1,098	80% FPL, 81% from 2019-06-01, 100% from 2022-07-01	Minn. Stat. 256B.056, subd. 5c(b), 4(a), 1c(a); Laws 2017, 1st Sp., ch. 6; Laws 2019, 1st Sp., ch. 9; EPM 2.3.3.4
UT	$1,012 / $1,372 (2018)	100% FPL	Utah Admin. Code R414-304-9(2); Utah Code 26B-3-108(9)(b)
WI	$592 / $592	100% FPL from 2019-09-01	Wis. Stat. 49.47(4)(c)1; Ops Memo 19-26; MEH 39.4.1 ($1,330.00 / $1,803.33 from 2/1/2026)
NY	$842 / $1,233	$934 / $1,367 in 2022; 138% FPL from 2023-01-01	GIS 22 MA/11; SPA NY-23-0001

Dollar limits updated

State	Before	After	Source
CT	$523 / $696	$653 / $879 (2022-07-01), $700 / $946 (2024-01-01), $723 / $980 (2024-03-01), $835 / $1,128 (2025-03-01), $851 / $1,153 (2026-03-01)	SPAs CT-22-0031, CT-24-0003, CT-24-0006, CT-25-0013 and CT-26-0006 (p7 of each); DSS chart 3/1/26
DC	$652 / $652	$780.58 / $821.67 (2023), $809.08 / $851.67 (2024), $837.19 / $881.25 (2025), $856.58 / $901.67 (2026)	29 DCMR 901.1 (2003); DHCF notice ($780.58, 2023); DHCF fact sheet ($809.08, 2024); KFF 2026 ($857 / $902)
NH	$591 / $675	$888 / $1,033 (2023-01-01), $916 / $1,066 (2025-01-01), $939 / $1,093 (2025-07-01)	SPAs NH-23-0029, NH-25-0012 and NH-25-0019 (p7 of each)
RI	$903 / $947	Each January 1 from 2019 to 2026, ending at $1,200 / $1,242	210-RICR-40-00-3 § 3.2.8(A)(8) and its 2020 version; SPAs RI-21-0004 (p4) and RI-22-0003 to RI-26-0001 (p7)
VT	$1,041 / $1,041 (2018)	The protected income level (PIL) outside Chittenden County, the same for one and two people: $1,091 (2020), $1,100 (2021), $1,166 (2022), $1,258 (2023), $1,300 (2024), $1,333 (2025), $1,375 (2026), each January 1	HBEE Part 2 § 8.06(b) (eligible if income is "at or below the PIL"); HBEE Part 5 § 29.14, pp. 50–52; DCF B17-26 (2018); DVHA 2020 PIL chart; DVHA Standards Change for Healthcare 2021–2025 and 2026 (p1 of each)

Asset limits updated

State	Before	After	Source
CA	$2,000 / $3,000	$130,000 / $195,000 from 2022-07-01; no limit in 2024–2025; $130,000 / $195,000 from 2026-01-01	Welf. & Inst. Code 14005.62 (a), (c), (d); ACWDL 21-31, 22-25 and 25-14 (p8 lists the aged, blind and disabled medically needy aid codes)
IL	$2,000 / $3,000	$17,500 / $17,500 from 2023-05-12	PM 07-02-01
NY	$15,150 / $22,200	$16,800 / $24,600 (2022), $30,182 / $40,821 (2023), $31,175 / $42,312 (2024), $32,396 / $43,781 (2025), $33,038 / $44,796 (2026)	GIS 22 MA/11 p2; GIS 23 MA/02, 24 MA/01, 25 MA/03 and 26 MA/05 attachments, p2

How the model applies them

• New variable medicaid_medically_needy_income_limit (person, annual). It returns one of three amounts:
  • fpg_rate times the poverty guideline for one or two people, when the state's fpg_rate is above zero;
  • otherwise, ssi_rate times the SSI federal benefit rate (individual or couple rate), when the state's ssi_rate is above zero;
  • otherwise, 12 times the monthly dollar limit.
• The individual or couple choice follows the marital unit, as in medicaid_optional_senior_or_disabled_income_limit (42 CFR 435.602).
• Merge after Count blind people and use the individual or couple in the Medicaid medically needy test #10370. On its own, this PR picks the income limit by marital unit, while income, assets and the asset limit stay on the tax unit. Count blind people and use the individual or couple in the Medicaid medically needy test #10370 moves those to the marital unit. The two PRs touch different lines of is_medically_needy_for_medicaid.py, so the Python merges cleanly. Both PRs, and Count income of aged, blind, or disabled people who fail SSI's noncitizen test #10240, append cases to is_medically_needy_for_medicaid.yaml, and Count blind people and use the individual or couple in the Medicaid medically needy test #10370 also appends to is_in_medicaid_medically_needy_category.yaml.
  • Resolving the test-file conflict. Git reports is_medically_needy_for_medicaid.yaml as two interleaved conflict blocks, and "Accept Both" splices the blocks mid-case, which gives invalid YAML. Instead, take Count blind people and use the individual or couple in the Medicaid medically needy test #10370's version of the file whole (its MA case and Cases 1-6), then append this PR's Cases 3-15 in their original order, renumbered 7-19.
  • In is_in_medicaid_medically_needy_category.yaml, keep Count blind people and use the individual or couple in the Medicaid medically needy test #10370's Cases 1-2, then this PR's Cases 3-4, which are already numbered to follow them.
• New limit.income.fpg_rate (IL, MN, ND, NY, UT, WI) and limit.income.ssi_rate (KS, WA). These files list only the states that use them. NY, WI and KS carry a zero share before their switch dates.
• New flag limit.income.couple_uses_individual_limit, true for Washington only. Washington's MNIL chart gives the one-person benefit rate to households of one and two people. Kansas's F-8 table gives couples the couple rate.
• The dollar files drop IL, MN, ND, UT and WA, whose rates apply from the files' first date (2018-01-01). Their 2018 dollar figures match the rate times the 2018 guideline or benefit rate, rounded up to the dollar.

Not confirmed against a primary source

• DC: DHCF publishes only the one-person level ($780.58 for 2023 and $809.08 for 2024). The couple levels and the 2025–2026 values follow the method in 29 DCMR 901.1 and its table: the two-person level is 50% of the two-person guideline, and the one-person level is 95% of that. This method reproduces both DHCF figures and KFF's 2026 figures, which KFF rounds to $857 / $902. Sources give values by year only, so the parameter dates them January 1.

• ND: no North Dakota document says when 90% replaced 83%. The manual shows 83% in April 2023 and 90% in April 2024. SPA ND-23-0034 (effective 2024-01-01) aligns the medically needy standards at 90%. Manual letter 3776 (1/1/2024) and the table in ML 3790 point to the same date, so the parameter uses 2024-01-01.

• NH: KFF 2026 lists $926 / $1,073. The CMS-approved SPA NH-25-0019 and NH's current manual tables show $939 / $1,093 from 2025-07-01, and the PR uses those.

• VT 2019: no 2019 PIL was found (DVHA's 2019 chart is not online or archived), so 2018's $1,041 stays in force through 2019.

• IL: IDHS does not state when it applies each year's new guideline. Illinois's Department on Aging says the figures post in early April.

• DC state plan: CMS-approved SPA DC-22-0014 (effective 10/1/2022, pp. 15–17) still lists the 1994 six-month levels, $2,262 / $2,382, or $377 / $397 a month. The PR follows 29 DCMR 901.1 and DHCF's notices. No statute is involved.

Limitations

• Vermont couples. HBEE 29.14 tests a couple against "the PIL or the SSI/AABD payment standard for two, whichever is higher", but spend-down reduces income to "the applicable PIL" (29.14(a)(iv)), and 8.06(b) sets the medically needy level at the PIL. So the medically needy limit here is the PIL alone. A couple between the PIL ($1,375) and the AABD couple standard ($1,596.80 in 2026) qualifies through the categorical aged, blind and disabled group (HBEE 8.05(b)), which draft Use state dollar standards for the Medicaid aged, blind and disabled income limit in AK, ID, NH, VT and WI #10378 encodes. Until Use state dollar standards for the Medicaid aged, blind and disabled income limit in AK, ID, NH, VT and WI #10378 merges, the model's Vermont ABD limit for couples is 80% of the FPL.
• Minnesota Title II COLA. Minnesota does not count the January Social Security increase until July 1 for these cases (Minn. Stat. 256B.056, subd. 1a(a)(3)). The annual model counts the full year's benefit.
• Connecticut. The medically needy test omits the MAABD unearned income disregard ($562 a month per member in 2026, UPM 5030.15), so Connecticut's countable income is too high. Follow-up issue Medicaid medically needy: state income exclusions in place of SSI's $20 (Illinois $25 per spouse; Connecticut's HUSKY C disregard per member; Minnesota none) #10472, which also covers Illinois's $25.
• Values dated after January 1 apply from the next calendar year, because the limits are annual and read parameters on January 1. Examples: Kansas's July 2025 switch applies from 2026; Connecticut's March 2026 amounts apply from 2027; New Hampshire's July 2025 amounts apply from 2026; Illinois's $17,500 (May 2023) applies from 2024; California's $130,000 (July 2022) applies from 2023.
• These variables are annual. They use the poverty guideline dated January 1 of the year. The states adopt new guidelines on their own schedules: MN July 1, WI February 1, ND April 1, Utah in March, and NY back-dated to January 1.
• States round to whole dollars (MN, NY and ND round up), but Wisconsin uses cents. The model does not round, so it can differ from a published limit by less than $1 a month.
• DC keeps $652 / $652 through 2022, and NY keeps its 2018 amounts through 2021. DCMR 901.1's method would give higher DC values for 2018–2022, and the NY GIS messages for 2019–2021 could not be retrieved.
• Connecticut set different limits by region from July 2021 to June 2022. This PR does not encode those regional amounts, so Connecticut keeps $523 / $696 until 2022-07-01.

Out of scope

• Michigan (issue Update Michigan SSI-related Medicaid asset limits and ABD pathways #8453).
• Regional limits in LA and VA, and Vermont's higher PIL inside Chittenden County ($1,483 in 2026; the PR applies the outside-Chittenden PIL statewide).
• Medically needy groups for pregnant women, children and parents.
• California's non-MAGI asset limit drops to $21,000 / $31,000 on 2027-07-01 (SB 164, Stats. 2026, ch. 27). Draft Lower California's non-MAGI Medi-Cal asset limit to $21,000 / $31,000 on July 1, 2027 #10375, stacked on this PR, encodes it.
• Massachusetts: KFF 2026 lists the aged and disabled medically needy limit at 100% FPL, against PolicyEngine's $522 / $650. Not checked against MassHealth rules.
• Illinois's $25 AABD income exemption, one per spouse with income (PM 15-04-03-a): the pathway uses SSI countable income, with one $20 exclusion. Follow-up issue Medicaid medically needy: state income exclusions in place of SSI's $20 (Illinois $25 per spouse; Connecticut's HUSKY C disregard per member; Minnesota none) #10472.
• The pregnant, child and parent medically needy flags have the same five swapped state pairs, and parent.yaml has more differences. Follow-up issue Medicaid medically needy: fix the pregnant, child and parent category flags against KFF and state sources #10473.

Test plan

• New medicaid_medically_needy_income_limit.yaml (18 cases, including Vermont's PIL for every year from 2018 to 2026):
  • year-keyed households (a couple plus a single relative) pin every dated CT, DC, NH and RI dollar value, NY's 2022 dollar value and 2023 rate, MN's 80% and 81%, ND's 83% and WI's 2019 dollar value;
  • one case per rate state at its current limit, plus Kansas before its July 2025 switch.
• New cases in is_medically_needy_for_medicaid.yaml:
  • a senior in each of AR, IA, NJ, IL and ND whose income exceeds the limit before medical expenses and meets it after. NJ's income is above the optional aged, blind and disabled limit, and ND's income after expenses equals its limit;
  • assets exactly at the IL ($17,500), CA ($130,000) and NY ($33,038) limits; CA one dollar over; CA in 2024 with no limit; NY at each year's level from 2022 to 2026;
  • NY, CA and IL couples at the 2026 couple asset limits;
  • a Vermont senior whose income after medical expenses equals the 2026 PIL ($16,500 a year, eligible) and one dollar a month over (ineligible).
• is_in_medicaid_medically_needy_category.yaml: disabled adults in AR, IA, IL, ND and NJ are in a medically needy category; a senior and a disabled adult in AZ are not.
• Updated an existing Kansas case in medicaid_medically_needy_medical_expenses.yaml. Under the 2026 limit ($11,928) the old income passed both ways. The case now uses countable income of $15,000, so it still distinguishes deducting pretax premiums once from deducting them twice.
• Source conflicts: none involving a statute. One non-statute conflict is disclosed above (DC's state plan against 29 DCMR 901.1).
• make format (ruff)
• Changelog fragment in changelog.d/
• CI passes (tests were not run locally)

No file in tests/policy/baseline/partners/ changes. By static reading, the partner Medicaid cases in these states are seniors who already qualify through the aged, blind and disabled pathway, and the medically needy pathway applies only to people outside every other pathway. CI will confirm once the PR is ready.

axiom: TheAxiomFoundation/rulespec-us#1938 queued

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