Texas TANF: Missing Features and Implementation Uncertainties

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[hua7450]

The Texas TANF implementation has some gaps and uncertainties that need to be documented and potentially addressed.

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Missing Features

1. One-Time TANF for Relatives (OTTANF-R)

Currently not modeled in the codebase.

Note: OTTANF and OTTANF-R are two separate programs.

References:

• Texas Works Handbook A-2410: https://www.hhs.texas.gov/handbooks/texas-works-handbook/a-2410-general-policy
• 1 Tex. Admin. Code Chapter 372, Division 5

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Implementation Uncertainties

1. Income Tests Logic: Part A vs Part B Appears Redundant

Issue: Applicants must pass both Part A and Part B of the Recognizable Needs Test:

• Part A: Uses 1/3 disregard (67% of income counts)
• Part B: Uses 90% disregard (10% of income counts)
• Both compare against same 25% recognizable needs threshold

Question: If someone passes Part A with the less generous 1/3 disregard, they should automatically pass Part B with the more generous 90% disregard. What scenario would cause someone to pass Part A but fail Part B?

Possible explanations:

• Part A only considers earned income; Part B includes unearned income
• Part A has fewer deductions; Part B includes dependent care and child support
• Different income types are tested

Current implementation: Built based on handbook description, but the logic seems redundant

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2. 90% Earned Income Disregard Calculation - Ambiguous Wording

Legal code: 1 Tex. Admin. Code § 372.409(a)(2)

"a disregard of 90% of earned income over $120"

Two possible interpretations:

(a) Current implementation:

1. Subtract $120 work expense → net income
2. Apply 90% disregard to all remaining income
3. Example: $1,000 gross → $880 net → disregard 90% ($792) → count $88

(b) Alternative interpretation:

1. Subtract $120 work expense → net income
2. First $120 of net income counts (threshold)
3. Apply 90% disregard only to amounts over $120
4. Example: $1,000 gross → $880 net → first $120 counts → remaining $760: disregard 90% ($684), count $76 → total countable = $196

Handbook language: "after subtracting the standard work-related expense, 90 percent of the remaining earnings" supports interpretation (a)

Current implementation: Uses interpretation (a)

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3. Applicant Fraction (1/3 Disregard) - Only in Handbook, Not Legal Code

Parameter: applicant_fraction.yaml = 0.33

Where found:

• ✅ Texas Works Handbook A-1425.2: "disregard of 1/3 of the remaining income"

Where NOT found:

• ❌ 1 Tex. Admin. Code § 372.409 (only mentions 90% disregard)
• ❌ 1 Tex. Admin. Code § 372.408 (describes tests but not specific 1/3 value)