[hua7450]

Adds Delaware LIHEAP regular heating assistance (the Delaware Energy Assistance Program's Fuel Assistance Program) for FY2026, heating season October 1, 2025 to April 30, 2026. Delaware pays one benefit from its FY2026 matrix. The model tests income less estimated federal, state and Wilmington taxes against 60% of state median income ($39,342 for one qualified member to $113,488 for twelve), keeps income below 110% of the 2025 poverty guideline eligible, places income in one of eight intervals of the limit, and reads one of five fuel schedules ($100 to $2,464). Subsidized tenants paying heat separately with rent up to $679 a month get a flat $236 instead.

Fixes #10606

Regulatory authority

• 42 U.S.C. 8624(b)(2)(B), income ceiling and 110% floor
• FY2026 LIHEAP Detailed Model Plan, sections 1.1, 1.4-1.9, 2.1-2.6 and 17.3, pages 4-7, 9-10 and 43
• 2026 Delaware Energy Assistance Program Benefit Matrix, approved April 28, 2025, page 1
• DEAP Policies and Procedures Manual (historical edition), sections 301, 401, 413-419, 424-427 and 429, pages 19, 25 and 31-42
• DHSS Utility Assistance overview
• LIHEAP IM 2025-02 Attachment 4, state median income for FY2026, pages 1 and 4
• 2025 HHS poverty guidelines, 90 FR 5917

Eligibility

Requirement	Source	How modeled
Delaware residence	Manual 401	defined_for = StateCode.DE
At least one citizen or qualified noncitizen	Manual 426-427; plan 17.3	de_liheap_household_size sums is_citizen_or_legal_immigrant; every member's income counts
Adjusted income at or below 60% of state median income	Plan 2.1; matrix	The shared liheap_smi_limit: 60% of the FY2026 four-person SMI ($126,099) floored to $75,659, times the 45 CFR 96.85(b) size factor, floored: all 12 printed limits
Federal floor	42 U.S.C. 8624(b)(2)(B); matrix note 4	Income below 110% of the 2025 guideline for the qualified size, rounded to cents, stays eligible; binds from 20 members
No categorical eligibility, assets test or SNAP nominal payment	Plan 1.4, 1.7a, 2.3	No bypass; assets ignored
Heating responsibility	Manual 413, 415; plan 2.3	has_heating_expense (a bill for the named fuel) or heat in unsubsidized rent; NONE is ineligible, UNSPECIFIED qualifies only with heat in rent
Subsidized heat in rent	Manual 424	Ineligible; subsidized means receives_housing_assistance or is_in_public_housing

Countable income

Item	Source	How modeled
Earned income, members 18 and over	Plan 1.9; manual 416.1, 418	Wages, military basic pay (military_basic_pay, entered apart from employment_income), self-employment (self_employment_income, sstb_self_employment_income), partnership and S corporation income, farm income, rental income (rental_income, farm_rent_income; manual 418.4 treats rent as earned) and other taxable income (miscellaneous_income). Net amounts are added as reported, so a business or rental loss offsets other income, including another member's; only the household total floors at zero
Unearned income, members 18 and over	Plan 1.9; manual 416.2, 419	Unemployment compensation (total_unemployment_compensation), Social Security and railroad retirement together net of the member's medicare_part_b_premium (floored at zero), SSI, pensions, military retirement with Survivor Benefit Plan annuities (military_retirement_income), IRA and 401(k) distributions (retirement_distributions), insurance disability payments (disability_benefits), strike benefits, trust income (estate_income), non-Social Security survivor benefits, general assistance, alimony, child support received, interest, dividends, veterans benefits, workers' compensation
Members under 18	Manual 418, 419.1	Only child support received, SSI, and Social Security and railroad retirement net of Part B (minor_unearned)
TANF	Plan 1.9	Take-up-gated tanf, once per household
Payroll taxes	Plan 1.8; matrix note 2	Subtract spm_unit_paycheck_withholdings (employee payroll tax, state withheld income tax, federal income tax before credits) and de_wilmington_earned_income_tax, less excluded members' payroll taxes, all their de_withheld_income_tax and Wilmington tax on their earnings; floored at zero
Excluded	Plan 1.9; manual 418, 429.2	All other income of members under 18; all income of a dependent full-time college student under 22, who stays in household size; cash gifts, gambling winnings, capital gains

Source-priority calls:

• Limit and income basis: the FY2026 matrix (note 2), plan 1.8 and the DHSS overview ("capped at 60% of Delaware's State Median Income (SMI) after federal and local taxes") are followed over the historical manual's 200% of the guideline and gross income (415, page 32).
• Strike benefits and insurance disability payments: the manual (416.2, page 33; 419.3, page 37) is followed over the plan's unchecked "Strike Pay" and "Insurance payments made directly to the insured" boxes (1.9, page 6), as ruled on 2026-11-02 (backlog us-de:liheap-plan-income-checklist). The manual's sections carry 2011-2015 dates, and the 2020 statement of work still lists it as an applicable document.
• Members under 18: manual 418 (page 35) counts only child support and Social Security benefits, while plan 1.9 unchecks only a child's earnings, so a reading of the plan alone would count a minor's other unearned income. The manual is followed, as ruled on 2026-11-03 (same backlog entry), and the 2020 statement of work, page 73 asks for income documentation only from members aged 18 and over not attending school.
• Trusts (estate_income) and other taxable income (miscellaneous_income): manual 416.2 and 416.1 fill what the plan does not list (same backlog entry).
• Part B: manual 419.1 (page 37) lists railroad retirement among Social Security benefits and plan 1.9 (page 7) nets health deductions from Social Security and pensions, so the premium nets against both.
• The manual also supplies the qualified-member, student, minor, rental-income and subsidized heat-in-rent rules. Its $5 SNAP payment (425) falls outside regular heating, and plan 1.7a answers No.
• Federal floor: the statute is followed (conflict register backlog us-de:liheap-income-floor-vs-smi-limit).

Benefit

Interval k covers adjusted income up to floor(limit x u/200), with u the matrix's upper "Income Percent Interval" (25.4999%, 50.4999% ... 175.4999%, 200%); this reproduces all 96 printed maximum incomes.

Interval (IPI)	Propane	Fuel oil, kerosene	Electric	Natural gas	Other
1 (0-25.4999%)	$2,464	$2,016	$1,391	$1,126	$726
2 (26-50.4999%)	2,108	1,724	1,190	963	621
3 (51-75.4999%)	1,751	1,432	988	800	516
4 (76-100.4999%)	1,043	853	588	476	307
5 (101-125.4999%)	697	570	394	318	205
6 (126-150.4999%)	502	411	283	229	148
7 (151-175.4999%)	380	311	215	174	112
8 (176-200%)	339	278	192	155	100

• The matrix's KERO and FUEL OIL columns are identical; wood, coal and OTHER use Other; heat in unsubsidized rent uses Electric for any heating_type but NONE (plan 2.3). No Delaware source lists solar heat: SOLAR with an electric bill uses Electric, an inference from heating_expense reading its electric bill.
• Subsidized tenants without heat in rent whose annual rent (tenant share after housing_assistance) is at most 12 x $679 receive $236; above that, the matrix (matrix note; plan 2.3).
• Federally protected income above the limit takes interval 8. No bill cap; priority points (60 or older, under 6, disabled) only order funding (plan 2.3-2.4).

Not modeled

Item	Source	Treatment
Application-period income	Manual 416	Annual income
Actual withholding	Plan 1.8	Estimated taxes: income_tax_before_credits ignores the child tax credit, includes federal tax on capital gains the PR does not count, and keeps federal tax on excluded members' wages. No tax is estimated on military_basic_pay
Pension health deductions, including Part B withheld from a civil-service annuity; Part D and Medicare Advantage premiums withheld from Social Security	Plan 1.9 (page 7)	Not observed; pensions count gross, and only Part B nets against Social Security and railroad retirement
Royalties, contract income and sales, military allotments, roomer payments, foster stipends, lump sums, recurring gifts	Plan 1.9; manual 416.2, 417.1, 418.5, 419, 429	Royalties only in rental_income; lump sums count; annual financial_assistance cannot identify gifts "received from the same source more than once a month"; the others have no input
Medical-bill deduction from indemnity benefits, veterans' education contribution, the state supplement (de_ssp)	Manual 419.3, 417.1(9), 416.2	Not represented; de_ssp recipients live in certified residential care homes
Roomers, nursing-home residents, separation, deaths, out-of-state students, funding order	Manual 429; plan 2.3	Not represented
Crisis, cooling, weatherization, equipment	Plan 1.1	Out of scope

The Clearinghouse file is named CO_BenefitMatrix_Heating_2026.pdf; its title and figures are Delaware's. Earlier years are unverified backfilled estimates; period 2027 carries the FY2026 matrix forward with FY2027 state median income.

Microsimulation: heating_type and the per-fuel bills, heat-in-rent and housing-assistance inputs are not in current datasets; callers must supply them.

Test plan

91 YAML cases in 7 files. The 90 cases at 59ba1b3ef5 passed in CI. The 2026-11-03 review fixes (military basic pay, a minor's railroad retirement, and eligibility Case 12 on the fuel guards) have not run; CI validates them.

• every column and interval, kerosene, wood and coal, the matrix example, the size-six interval 7 edge, all 12 limits and every interval maximum with the next dollar;

• heat in unsubsidized rent (natural gas, unspecified fuel, no heating), a directly set heating expense with no heating or an unknown fuel, subsidized heat in rent, the $679 ceiling ($8,148, $8,148.12, $8,160 a year), tenant rent after housing assistance, public housing with separate heat and with heat in rent, and solar with an electric bill;

• noncitizen parents, dependent students under and at 22, minors' income (support, SSI and survivors only), each counted and excluded source, monthly SSI, Social Security and railroad retirement net of Part B, a business loss within one person and across members, military basic pay, a minor's railroad retirement, TANF, estimated payroll, state and Wilmington taxes with excluded minors, including nonresident earnings, 25 members under the federal floor, no assets test or SNAP route, and a mixed-state batch.

• YAML tests with expected values from the FY2026 matrix, plan and historical manual

• Source-conflict register entry for a statute reading (backlog entries us-de:liheap-income-floor-vs-smi-limit and us-de:liheap-plan-income-checklist in source_conflicts/candidates.yaml; no # Source conflict marker until they are registered)

• make format

• Changelog fragment in changelog.d/

• CI passes

axiom: TheAxiomFoundation/rulespec-us#1994 queued

🤖 Generated with Claude Code

[codecov]

Codecov Report

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✅ Project coverage is 100.00%. Comparing base (b540912) to head (ab98aa9).
⚠️ Report is 95 commits behind head on main.

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[DTrim99]

PR Review: Add Delaware LIHEAP regular heating assistance

PR #10612 (author: hua7450), head 59ba1b3ef5. This is a first review. The PR adds Delaware's regular heating benefit for FY2026, with a heating season of October 1, 2025 to April 30, 2026. The benefit is the Fuel Assistance Program of the Delaware Energy Assistance Program (DEAP), which DHSS runs with Catholic Charities and First State Community Action Agency as intake agencies. The PR includes:

• 15 parameters and 7 variables under gov.states.de.dhss.liheap;
• 7 test files (90 cases);
• a programs.yaml entry, plus DE on the LIHEAP coverage line;
• one source_conflicts/candidates.yaml backlog entry (us-de:liheap-income-floor-vs-smi-limit);
• a changelog fragment.

The PR has no reviews yet; the only comment is Codecov's. It touches no partner test file.

Path prefixes:

• P/ = policyengine_us/parameters/gov/states/de/dhss/liheap/
• V/ = policyengine_us/variables/gov/states/de/dhss/liheap/
• T/ = policyengine_us/tests/policy/baseline/gov/states/de/dhss/liheap/

Sources read for this review:

• State plan: the accepted FY2026 Detailed Model Plan, pages 1, 4-7 and 9-10. The text layer drops the check-box states, so I read items 1.4, 1.7a, 1.8, 1.9 and 2.3 from page renders.
• Benefit matrix: the 2026 DEAP Benefit Matrix, approved April 28, 2025. The Clearinghouse file is named CO_..., but its title and figures are Delaware's.
• Manual: the DEAP Policies and Procedures Manual, pages 19, 31-33, 35 and 37-42. Its sections carry 2011-2015 issue and revision dates.
• 2020 statement of work: the LIHEAP RFP HSS-20-036 statement of work, pages 69, 72-73 and 78. It lists the manual as an applicable document, and it says ineligible members count toward income but not toward size.
• DHSS: the DHSS Utility Assistance page, as served on 2026-11-02.
• Federal: LIHEAP IM 2025-02 Attachment 4, pages 1 and 4, and 42 U.S.C. 8624(b)(2)(B).
• Not found: I found no Delaware Administrative Code chapter on DEAP eligibility. The Clearinghouse has no FY2027 Delaware plan or matrix.

Summary

What is right. The FY2026 matrix is encoded faithfully, and most of the structure follows the plan, the matrix and the manual.

• Income limits. The shared liheap_smi_limit gives floor(floor(0.6 × $126,099) × size factor). That reproduces all 12 matrix limits, from $39,342 to $113,488, and HHS's Attachment 4 figures exactly. The limit is never above the 8624(b)(2)(B) ceiling. The 110% floor (strict, rounded to cents, on the 2025 guideline) first binds at 20 members.
• Intervals and amounts. floor(limit × u/200) reproduces all 96 printed maximum incomes; I recomputed every cell. The 48 fuel amounts, the $236 flat award and the $679 rent ceiling match the matrix.
• Arrangements. Kerosene takes the KERO column, which equals fuel oil. Heat in unsubsidized rent takes Electric (plan 2.3), and subsidized heat in rent is ineligible (manual 424).
• Household. Size counts only qualified members, but every member's income counts (manual 426; 2020 SOW p. 78). Dependent full-time students under 22 stay in the size, but their income is excluded (429.2).
• Income. Income is reduced by estimated federal, state and Wilmington taxes (plan 1.8, matrix note 2). Social Security and railroad retirement are netted of the computed Part B premium (plan 1.9 "Excluding MediCare deduction"), floored per person. total_unemployment_compensation, military_retirement_income and railroad_benefits are counted.
• Tests. I hand-checked 15 expectations, and CI ran all 90 cases green.

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

• S1. Military basic pay. military_basic_pay is not counted.
• S2. Manual over plan. Three income rules follow the 2011-2015 manual over the FY2026 plan's item 1.9, and nothing records the choices: strike pay, insurance disability payments and minors' unearned income.
• S3. Unpinned logic. No test pins the minors' railroad_benefits entry or the heat-in-rent NONE guard.
• S4. Descriptions. Two parameter descriptions are off the house template.

There are also six suggestions (G1-G6):

• G1: two unreachable guards;
• G2: the withholding estimate;
• G3: losses offsetting income across tax units;
• G4: health deductions the model can't see;
• G5: FY2027;
• G6: housekeeping.

Status.

• CI: 36 of 36 checks pass at the head.
• Branch: 9 commits ahead of main (4 of them merges) and 12 behind. It merges cleanly.
• Siblings: the PR shares the LIHEAP coverage line and candidates.yaml with seven open wave PRs (branch note).

Critical (must fix)

None.

Should address

S1. Military basic pay is not counted

• Where: P/income/sources/earned.yaml:4-14 lists eight sources but not military_basic_pay: employment_income, self_employment_income, sstb_self_employment_income, farm_operations_income, partnership_s_corp_income, rental_income, farm_rent_income and miscellaneous_income. In this model, basic pay is a separate input from employment_income.
• Sources:
  • Plan 1.9 (p. 5) checks "Wages".
  • Manual 416.1 (p. 33) counts "Gross wages from employment" and "Salary".
  • Manual 418.1 (p. 35) counts "all gross wages, salaries, commissions, bonuses, profit sharing, and tips of an employee".
  • Nothing excludes service pay.
• Effect (period 2026; a single service member aged 25 whose only income is military_basic_pay; natural gas heat with a $1,000 gas bill):
  • $50,000: the head counts $0 and pays band 1, $1,126. Counted, the pay stays above the limit even net of about $9,700 of estimated FICA, federal and Delaware income tax. About $40,300 is above $39,342, so $0.
  • $25,000: the head pays $1,126. Net of about $3,500 of those taxes, about $21,500 is band 5 and pays $318. If no tax is deducted on basic pay, $25,000 is band 6 and pays $229.
• Severity: should. The wave rated this omission a should in CO Add Colorado LEAP regular heating assistance #10609 S3, SC Add South Carolina LIHEAP regular heating assistance #10616 S3 and WV Add West Virginia LIEAP regular heating assistance #10618, as well as UT, AK and PA. The AK, IA, ND, NV and UT LIHEAP lists on main count military_basic_pay. Dover Air Force Base makes the case common in Delaware.
• Fix:
  • Add military_basic_pay after employment_income, with the Iowa/North Dakota comment about entering basic pay in only one of the two.
  • Give it a distinct positive amount in T/income/de_liheap_countable_income_person.yaml Case 1.
  • Update the body's earned-income row and the Axiom issue's earned sources.

S2. Three income rules follow the historical manual over plan item 1.9, and nothing records the choices

• Where:
  • Strike pay and insurance disability payments. P/income/sources/unearned.yaml:25-29 counts disability_benefits and strike_benefits. Its comment says the manual is followed over the plan's unchecked boxes. T/income/de_liheap_countable_income_person.yaml Case 11 (strike pay of $3,000) and Case 14 (disability payments of $2,400) pin them.
  • Minors. At V/income/de_liheap_countable_income_person.py:29-37 and P/income/sources/minor_unearned.yaml, members under 18 count only child support, Social Security, SSI and railroad retirement. Person Case 14 (a minor's $500 of interest) and Case 15 (a minor's $2,000 of trust income) pin those exclusions.
• Sources:
  • Plan 1.9 in the accepted FY2026 plan (pp. 6-7):
    • "Strike Pay" is unchecked, and so is "Insurance payments made directly to the insured".
    • The only person-based exclusion is "Earned income of a child under the age of 18", also unchecked. So a child's unearned income of a checked type counts: VA benefits, "Interest, dividends, or royalties", "Retirement / pension benefits" and others.
  • The manual:
    • 416.2 (p. 33) lists "g) Strike benefits".
    • 419.3 (p. 37): "Such disability payments made by an insurance company directly to the individual are counted as unearned income."
    • 418 (p. 35): "Income for household members under 18 is not counted towards households' income. This does not include child support or Social Security income."
  • The manual's currency.
    • Its sections carry 2011-2015 dates. The 2020 statement of work (p. 69) still lists it as an applicable document.
    • The PR's own Axiom issue (interpretation 1) says of the manual rules: "Their currency for FY2026 is not confirmed."
    • On minors, the statement of work (p. 73) asks for income documentation only "for all household members aged eighteen (18) and over if not attending school". That supports the manual.
• Why it is a finding.
  • On these three points the current accepted plan answers the question, and the head follows an older manual instead.
  • For strike pay and insurance payments, the body says only that the manual "is followed over" the plan. It gives no basis.
  • For minors, the body doesn't flag a conflict at all. Only Axiom interpretation 7 notes that "a reading of the plan alone would count a minor's unearned income other than these".
  • candidates.yaml holds only the federal-floor entry.
  • The wave rates a manual reading taken over the governing document without a reviewed record as should: MT, UT, AK r2 S1, PA S2, CO Add Colorado LEAP regular heating assistance #10609 S1-S2, and SC Add South Carolina LIHEAP regular heating assistance #10616 S4 on the same minors question.
  • The canons cut both ways. "Later over earlier" favors the plan on strike pay and insurance payments. On minors, "specific over general" and the 2020 statement of work may support the head. A record is where that basis belongs.
• Effect (period 2026; natural gas heat with a $1,000 gas bill):
  • Insurance disability payments. One adult aged 40 with $20,000 of disability_benefits (withholding supplied as 0, as in the PR's tests). The head counts $20,000, which is band 5, and pays $318. Under plan 1.9 nothing counts, so band 1 pays $1,126. At $40,000 the head pays $0 and plan 1.9 still pays $1,126.
  • Minors' unearned income. A parent aged 35 with $30,000 of child support received and a child aged 10 with $22,000 of veterans_benefits (dependency and indemnity compensation). The head counts $30,000, which is size-2 band 5, and pays $318. Plan 1.9 counts $52,000, above $51,448, so $0.
• Fix: do one of the following.
  • (a) Follow plan 1.9. Drop strike_benefits and disability_benefits. Give members under 18 the checked unearned sources, still excluding their earnings.
  • (b) Keep the head's readings and add a candidate, for example us-de:liheap-plan-income-checklist, as LA and MN did:
    • cite plan 1.9 pp. 6-7, manual 416, 416.2, 418 and 419.3, and the 2020 statement of work p. 73;
    • give both readings, follows, and state: ruled with the basis;
    • also record the plan-silent gap-fills taken from the manual: trusts (estate_income) and "other taxable income" (miscellaneous_income, 416.1(f)).
  • Either way, update the body's source-priority notes and Axiom interpretations 1 and 7.

S3. Two pieces of logic no test pins

• The minors' railroad_benefits entry (P/income/sources/minor_unearned.yaml:9).
  • No test gives a member under 18 railroad benefits. Person Cases 14 and 16 give them only to adults, so deleting the entry fails no test.
  • The case is reachable: the Railroad Retirement Board pays children's survivor annuities.
• The heat-in-rent NONE guard ((fuel != types.NONE) at V/eligibility/de_liheap_eligible.py:44).
  • No test combines heat in rent with NONE. The heat-in-rent cases use NATURAL_GAS, UNSPECIFIED and SOLAR.
  • Without the guard, an unsubsidized NONE household with heat in rent becomes eligible and is paid the Electric amount ($1,391 at band 1). Deleting the guard fails no test.
• Severity: should, under the mutation rule. Wave 3 rates a reachable guard that no test pins a should, and so did UT r2 N1, ND r2 N1 and AK r3 N2.
• Fix:
  • Give a minor in person Case 14 a distinct railroad amount, for example $1,500, and raise the expected value by it.
  • Add an unsubsidized NONE row with heat in rent, expected false, to T/eligibility/de_liheap_eligible.yaml.

S4. Two parameter descriptions are off the house template

• The two descriptions:
  • P/payment/subsidized_amount.yaml: "Delaware provides this flat Low Income Home Energy Assistance Program benefit to subsidized households paying separately for heat with tenant rent at or below the ceiling."
  • P/payment/subsidized_rent_ceiling.yaml: "Delaware pays a flat Low Income Home Energy Assistance Program benefit to subsidized households paying separately for heat when monthly tenant rent does not exceed this amount."
• Why it is a finding. The template ends with "under the Low Income Home Energy Assistance Program", with nothing after the program name (NJ S6). The other 13 descriptions follow it.
• Fix: for example:
  • "Delaware provides this flat benefit to subsidized tenants who pay for heat separately and whose rent is at or below the ceiling under the Low Income Home Energy Assistance Program."
  • "Delaware limits the monthly tenant rent for the subsidized-housing flat benefit to this amount under the Low Income Home Energy Assistance Program."

Suggestions

G1. Two unreachable guards.

• & ~heat_in_rent in the flat-benefit test (V/de_liheap.py:49). Eligibility already bars subsidized heat in rent, so an eligible unit never reaches it with heat in rent.
• known_fuel in the non-rent branch (V/eligibility/de_liheap_eligible.py:38, 45). has_heating_expense is already false for NONE and UNSPECIFIED. The guard matters only when that input is supplied directly, and even then de_liheap pays $0 through the select default.
• Deleting either fails no test. Remove them, or add a one-line comment that they never bind.

G2. The withholding estimate. spm_unit_paycheck_withholdings adds income_tax_before_credits. That has three effects:

• it ignores the child tax credit, which a Form W-4 Step 3 claim takes out of an employer's withholding;
• it includes federal tax on capital gains, which the PR doesn't count as income;
• it keeps federal tax on excluded members' wages (body: "federal tax not split by person").

Los Angeles and Marin general relief use the same proxy, and the body calls it an estimate. Spell out these three effects in the body and in Axiom interpretation 5.

G3. Losses across tax units.

• What the manual reads. Manual 418.3 (p. 35) reads the self-employed person's Form 1040 adjusted gross income. On that reading a loss offsets other income on the same return, which is the spouses' case in T/income/de_liheap_countable_income.yaml Case 10.
• What the head does beyond that. It also lets a loss offset income outside AGI, such as child support, and income of members on other returns, such as an adult child's business loss against a parent's Social Security.
• Fix. Floor the offset at the tax unit, or record the reading.

G4. Health deductions the model can't see. Plan 1.9's "Other" box (p. 7) says "For social security and pensions, countable income is gross income minus health deductions." The head nets only Part B, and only against Social Security and railroad retirement. Two gaps belong in the body's "Not modeled" table:

• Civil-service annuities. OPM deducts Part B from the annuity of an annuitant who doesn't get Social Security. The head counts that pension gross, and person Case 13 pins Part B never reducing a pension.
• Part D and Medicare Advantage premiums withheld from Social Security. Main has no input for them.

G5. FY2027.

• No FY2027 Delaware plan or matrix is on the Clearinghouse.
• Period 2027 carries the FY2026 matrix and interval rates forward with the FY2027 SMI ($129,424). It isn't claimed, and the body says so.
• Add 2026-10-01 values once the FY2027 matrix is published.

G6. Housekeeping.

• programs.yaml: the DE entry is appended after WY, inside the alphabetical IL-WY run of the LIHEAP state_implementations. Move it to the unordered head of the list, for example next to DC.
• Test plan: the body says the newest cases "were not re-run" and leaves "CI passes" unchecked. CI passed on this head.
• Axiom issue:
  • companion test 7 still says "Case 37 is new and was not run";
  • lines 5 and 18 name main at e736b11708, though the head now merges main at 4bfc548de3.

Verified correct

• Limits and the federal floor.
  • floor(floor(126,099 × 0.6) × f(n)) gives 39,342; 51,448; 63,553; 75,659; 87,764; 99,869; 102,139; 104,409; 106,679; 108,948; 111,218; and 113,488. These match the matrix and HHS Attachment 4 (pp. 1 and 4) exactly.
  • The 60% SMI limit is never above the 8624(b)(2)(B) ceiling. At size 12, 150% of the guideline ($114,225) exceeds the limit, which is allowed.
  • The 110% floor uses the qualified size, the 2025 guideline (fpg_year_lag 1), rounding to cents and a strict "less than". It first binds at 20 members: $132,165 against $131,646.
  • The floor is recorded as backlog candidate us-de:liheap-income-floor-vs-smi-limit.
• Intervals and amounts.
  • All 96 printed maximum incomes equal floor(limit × u/200). The float64 cast at V/de_liheap_income_band.py:19 keeps the size-6 band-7 edge at $87,634 (Cases 25-26).
  • Protected income above the limit takes interval 8 (Case 36).
  • The five fuel columns match the matrix in all eight rows: propane $2,464-$339; KERO = fuel oil $2,016-$278; electric $1,391-$192; natural gas $1,126-$155; other $726-$100. These match plan 2.6's $100 minimum and $2,464 maximum.
  • Wood and coal, which manual 301 names, take Other. No benefit path can go negative.
• Arrangements.
  • Manual 415 (p. 32) requires the applicant to "be responsible for paying a heating bill in order to receive assistance for heating". So requiring a bill for the named fuel and barring NONE follows Delaware's own rule. This differs from SC Add South Carolina LIHEAP regular heating assistance #10616 S2, where the state asked only for an energy bill.
  • Unsubsidized heat in rent pays Electric for any fuel but NONE (plan 2.3, "the fuel type for the benefit is determined to be electric").
  • Subsidized heat in rent is ineligible (manual 424). "Subsidized" includes public housing (eligible Case 11; de_liheap Case 37).
  • Subsidized tenants with separate heat and annual rent of at most 12 × $679 get $236, and above that the matrix (Cases 13-16 and 34).
  • UNSPECIFIED outside the rent pays $0 (the Default heating_type to electricity and remove the UNSPECIFIED-gated state heating adapters #9754 convention) and is pinned.
  • Solar with an electric bill is read as electric, an inference the body documents.
• Household.
  • Size counts is_citizen_or_legal_immigrant, and all members' income counts (manual 426; 2020 SOW p. 78: "Ineligible members of the household are counted toward household income but not counted toward household size").
  • Dependent full-time students under 22 stay in the size, but their income and taxes are excluded (429.2).
  • There is no categorical eligibility, SNAP nominal payment or assets test (plan 1.4, 1.7a and 2.3). Priority points only order funding (plan 2.3-2.4).
• Income.
  • Adjusted income subtracts the estimated payroll, state and federal taxes and the Wilmington earned income tax (plan 1.8: "Adjusted Gross Income by deducting federal, state, city payroll taxes"). The PR removes excluded members' payroll, state and city taxes and floors the result at zero.
  • Social Security and railroad retirement are netted of the computed medicare_part_b_premium (net of MSP, per person, floored), the pattern the wave accepted. Part A doesn't matter here, because Social Security recipients get premium-free Part A.
  • Every checked plan 1.9 item that has an input is counted, among them TANF (take-up-gated, once per household), general assistance, SSI summed over the months, VA benefits, interest, dividends and workers' compensation (plan p. 7). Gifts, lump sums, tax refunds and capital gains are excluded.
• Batch checks.
  • Integrate modeled state unemployment insurance into income flows #9558, Count military SBP annuities in state benefit income lists #10317 and Count each Social Security benefit once in Pennsylvania CCW countable income #10408: total_unemployment_compensation and military_retirement_income are listed (SBP included, item 16). The list carries only the social_security aggregate and non-Social Security survivor_benefits, so nothing is counted twice (person Case 10).
  • Tie source-conflict markers to the register shared with Axiom #10287 ratchet: CI's guard tests pass, and the guard files are unchanged on main since the merge base. The PR changes no KNOWN_UNMARKED count.
  • NH Add New Hampshire state supplementation for 2026 #10156: the state-gated int de_liheap_income_band is the only key variable. V/de_liheap.py:19 raises it to at least 1, and de_liheap Case 24 runs DE, CT and MD households together. Size enters only arithmetically.
  • Item 17: main has de_ssp, and SNAP counts it. The body explains its omission: recipients live in certified residential care homes, where residents rarely hold the heating bill that manual 415 requires. That is sound.
• Mutation. Every adult earned and unearned list entry, the minors' child support, Social Security and SSI, every fuel branch and every eligibility and flat-benefit branch carries a distinct positive case, except the two items in S3 and the guards in G1.
• Housekeeping.
  • References use file pages that show their values, and multi-page titles use the #page a-b form.
  • The changelog fragment is top-level.
  • verified_years: "2026" is backed by period-2026 tests. Earlier years are unclaimed and documented as backfilled.
  • There is no aggregate wiring to copy.

Hand checks (period 2026; limit L(n); band maximum M_k(n) = floor(L(n) × u_k/200)):

1. T/de_liheap.yaml Cases 9-10: size 3, L = 63,553. Income $31,935 is M_4 → electric $588. $31,936 is band 5 → $394, the matrix's own example.
2. Cases 11-12: unsubsidized heat in rent at $31,936 takes band 5 Electric → $394 for both natural gas and unspecified fuel.
3. Cases 13-16: 8,148 ÷ 12 = $679.00 → $236. $8,148.12 and $8,160 go to the matrix: gas band 1 → $1,126. Rent of 12,000 − 3,852 = 8,148 → $236.
4. Cases 18-19: VA benefits of $39,342 = L(1) → band 8, Other → $100. $39,343 is over the limit and not below 1.1 × 15,650 = 17,215 → $0.
5. Case 20: 21,000 − 1,000 = 20,000. Size 1: M_4 = 19,769 < 20,000 ≤ M_5 = 24,687 → electric $394.
6. Case 21: size 2 with the student's income excluded. 12,990 < 16,000 ≤ 19,421 → band 3 gas → $800.
7. Case 22: 10,000 − 1,000 = 9,000. 5,016 < 9,000 ≤ 9,933 → band 2 gas → $963.
8. Cases 25-26: L(6) = 99,869. 99,869 × 0.8774995 = 87,634.998 → M_7 = 87,634 → gas $174. $87,635 → band 8 → $155.
9. Case 27: the minor's taxes are removed, so income is 26,000. Size 2: 25,852 < 26,000 ≤ 32,283 → band 5 gas → $318.
10. Case 33: 40,000 − 2,400 = 37,600. 34,522 < 37,600 ≤ 39,342 → band 8 gas → $155. Military retirement of $60,000 → $0.
11. Case 34: subsidized solar with rent of 7,200 or 8,148 → $236. Unsubsidized, or rent of 8,160 → electric band 1 → $1,391. No bill, NONE, or subsidized heat in rent → $0.
12. Case 36: L(25) = floor(75,659 × 1.89) = 142,995, and the floor is 1.1 × (15,650 + 24 × 5,500) = 162,415. $150,000 → band 8 gas → $155. $162,415 is not "less than" the floor → $0.
13. T/income/de_liheap_countable_income.yaml Case 1: 10,000 + 3,000 + 12 × 200 − (800 + 150 + 50) − 125 = 14,275.
14. T/income/de_liheap_countable_income_person.yaml:
    • Case 2: 100 + 200 + ... + 1,200 = 7,800.
    • Case 16: 41,000 − 2,434.80 = 38,565.20; 6,000 + 6,000 − 2,400 = 9,600; railroad of 1,000 nets to 0, and the pension of 1,000 stays → 1,000.
15. T/eligibility/de_liheap_eligible.yaml Case 1: all 12 limits are inclusive, and the next dollar is ineligible at every size (each is above 110% of the guideline, for example 1.1 × 76,150 = 83,765 at size 12).

Axiom line assessment

axiom: TheAxiomFoundation/rulespec-us#1994 queued is valid at this head.

• Status. The issue is OPEN, labelled pe-parity, and was last updated on 2026-11-02 at 16:58 UTC.
• Head. It describes dc180f1ad9. The head 59ba1b3ef5 only merges main on top of that, and its Delaware code, tests, programs.yaml entry and candidate are identical.
• Dispatch-ready. It has:
  • the blockers (sources missing from the corpus, the signed release not checked, no billed-run approval, no reviewed oracle revision);
  • module paths with corpus status;
  • verbatim text from the plan, the matrix, the manual and the federal sources;
  • Required outputs for all seven variables;
  • 14 companion tests derived from those sources rather than from PolicyEngine output.
• Interpretations. Interpretations 1 and 7 already flag the manual-over-plan readings in S2.
• Remaining work.
  • After S1-S3, update the earned sources and minors' list in Required outputs, companion tests 6, 10 and 11, and interpretations 1 and 7.
  • Fix the slips in G6.
  • Repoint the issue to the new head.

CI status

All 36 checks pass at 59ba1b3ef5 (run 41500817842, started 2026-11-02 18:27 UTC). That includes:

• PR validation (guard tests, lint, changelog);
• the baseline state shards that run the Delaware YAML;
• Household API Partners.

I re-checked near the end: 36 pass, none pending.

Branch status

• Position. The branch is 9 commits ahead of main (4 of them merges) and 12 behind. git merge-tree --write-tree against main is clean.
• Main's newer commits. Main's 12 newer commits include Count railroad retirement annuities as SSI unearned income #10534 (railroad retirement in SSI unearned income), Count only taxable wages in the child and dependent care credit's earned income limit #10520, Lock policyengine-core 3.34.2 #10589 (the policyengine-core 3.34.2 lock), Count the pre-2018 miscellaneous deduction once in Mississippi and Missouri itemized deductions #10096, Compare federal school meal income limits at USDA's whole-dollar thresholds #10384 and Lower California's non-MAGI Medi-Cal asset limit to $21,000 / $31,000 on July 1, 2027 #10375.
  • None touches Delaware LIHEAP, the shared SMI or poverty helpers, the heating inputs or the code-health guards.
  • Count railroad retirement annuities as SSI unearned income #10534 lowers computed SSI for railroad annuitants. This PR counts SSI and railroad_benefits once each, so nothing is double counted.
• Merged tree. The programs.yaml LIHEAP coverage line keeps all of main's states plus DE, with no duplicate implementation.
• Siblings. CA Add California LIHEAP regular heating assistance #10607, CO Add Colorado LEAP regular heating assistance #10609, CT Add Connecticut CEAP regular heating assistance #10611, ID Add Idaho LIHEAP regular heating assistance #10613, HI Add Hawaii LIHEAP regular heating eligibility and subsidized-dwelling benefit #10614, SC Add South Carolina LIHEAP regular heating assistance #10616 and WV Add West Virginia LIEAP regular heating assistance #10618 edit the same coverage line and candidates.yaml (branch note only).

Verdict: REQUEST_CHANGES

[DTrim99]

Requesting changes: 0 critical, 4 should (military basic pay not counted; strike pay, disability insurance and minors' unearned income follow the old manual over the FY2026 plan with no record; two unpinned entries/guards; two descriptions off-template). Full report in the comment above.

[hua7450]

Addressed in ab98aa9fac. These fixes haven't run yet, so this head's CI run is their first. The PR body and the Axiom issue are updated.

Applied

• S1. military_basic_pay now counts as an earned source, pinned in person Case 1 (28,500). The tax estimates don't deduct anything on it, so your $25,000 example pays $229, not $318. The parameter comment and the body say so.
• S2. Option (b): the three readings stay, recorded as us-de:liheap-plan-income-checklist, state: ruled. Strike pay and insurance disability were ruled on 2026-11-02 and minors' income on 2026-11-03, all following the manual. The entry also records the trust and other taxable income gap-fills.
• S3. A minor's railroad retirement is pinned in person Case 14 (8,700), and unsubsidized NONE with heat in rent in eligibility Case 12.
• S4. Both descriptions use your wording.
• G1. ~heat_in_rent is gone from the flat-benefit test.
• G2 and G4. The withholding effects and the health deductions are spelled out in the body and the Axiom issue.
• G6. The registry entry moved next to DC. The test plan and the Axiom issue's stale SHAs are fixed. "CI passes" stays unticked until this head finishes.

Not applied

• G1, known_fuel. Kept. If has_heating_expense is set directly, removing it lets NONE or UNSPECIFIED reach the flat branch, which pays $236 before the select default applies. Eligibility Case 12 pins it, with a one-line comment on the guard.
• G3. Cross-member loss netting stays, as ruled. The reading is recorded in the code comment, the body and Axiom interpretation 9.
• G5. No change: no FY2027 plan or matrix is published yet.