C-015
The gap register is itself a finding, not an empty placeholder
Section 13 names programs where the record does not support a defensible citizenship breakout and refuses to fabricate missing values.
Sources
S-076
Section 13 - Version 1.0 LOCKED
Programs Without Citizenship Breakouts
Gap register for programs where the public record does not support a defensible status-based spending figure.
Audit contents — Section 13
Structured Verification
Trace this section from the data model.
Summary: Gap register for programs where the public record does not support a defensible status-based spending figure.
Claims: 1
Claim links: C-015
Sources
None linked yet
Decisions
D-021
Open Questions
A-034 A-035 A-036
Related Sections
Section 7 Section 8 Section 10 Section 11 Section 12 Section 15
Claims In This Section
Reviewers should be able to move from section to claim without leaving the generated evidence path.
13.K Key Findings
- This is the audit’s central documented finding: for these programs the non-citizen-specific federal figure cannot be derived from primary evidence, and no estimate is fabricated.
- The deliverable is a gap register identifying the program, agency, reason, and evidence that would resolve it. No figure is assigned; no gap is zeroed or summed.
13.1 Gap register (no figures)
| Program | Agency / reason no breakout exists | Evidence that would resolve it | Open question |
|---|---|---|---|
| Eligible-immigrant Medicaid spend (from Section 7) | CMS per-status spending not published | T-MSIS status-spending tabulation | A-023 |
| Undocumented-only emergency Medicaid (from Section 7) | CMS T-MSIS cannot isolate undocumented population | T-MSIS undocumented indicator | A-024 |
| SNAP non-citizen benefit dollars (from Section 8) | USDA-FNS publishes counts, not benefit dollars net of citizen children | Quality-control benefit-by-status tabulation | A-025 |
| WIC and School Lunch / Breakfast (from Section 8) | USDA-FNS does not collect status condition | Participant status data not currently collected | A-026 |
| TANF non-citizen dollars (from Section 9) | HHS-ACF does not publish by status; citizen-child dominated | ACF status-expenditure data | A-027 |
| ACTC / CTC via ITIN (from Section 9) | IRS does not publish by status; mostly citizen-child | IRS ITIN-credit-by-child-status | A-029 |
| Eligible-noncitizen housing (from Section 10) | HUD does not publish by status; proration gives $0 to ineligible | HUD status-prorated outlay | A-030 |
| Federal K-12 share for non-citizens (from Section 11) | Plyler means status is not collected | None collectable under current law | A-032 |
| Eligible-noncitizen federal student aid (from Section 11) | ED does not publish by detailed status | Title IV aid-by-status | A-033 |
| Head Start; CCDF / SSBG / CSBG / LIHEAP (from Sections 11/12) | HHS status-neutral; state status reporting not required | Status reporting not required | A-034 |
| FQHCs; public health; FEMA disaster | HRSA / CDC / FEMA universal or emergency provision | Status-coded outlays mostly absent | A-035 |
13.2 Treatment
Total A contribution is a documented gap, not a number. Total B, where dollars do flow, is generally captured by U.S. providers such as hospitals, schools, clinics, and landlords. This register is the empirical backbone of the transparency thesis developed further in Appendix B and Section 15.
13.HR Hostile review
“Section 13 gaps are convenient omissions that let you cherry-pick.” This does not land. Each gap names the owner, agency, and exact data product that would resolve it. Gaps are never zeroed or summed. The gap is the finding. The section survives hostile review.
13.QA / LOCK
No figure is fabricated; every gap is typed and attributed; each is cross-referenced to Section 14 Table 14-G and Section 15. Section 13 is locked in Version 1.0.