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LIHEAP IM 2014-3 Best Practices Identified During Compliance Reviews Conducted in FY 2011, FY 2012, and FY 2013

Published: November 27, 2013
Low Income Home Energy Assistance Program (LIHEAP)
Guidance, Policies, Procedures, Information Memorandums (IM)


Information Memorandum

U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of Energy Assistance
370 L'Enfant Promenade, S.W.
Washington, D.C. 20447

Transmittal No.  LIHEAP-IM-2014-3                          Date: November 27, 2013


SUBJECT:    Best practices identified during compliance reviews conducted in FY 2011, FY 2012, and FY 2013.

RELATED           Low Income Home Energy Assistance Act, as amended (Title XXVI of
REFERENCES:   Public Law (P.L.) 97-35, the Omnibus Budget Reconciliation Act of 1981, as amended).

BACKGROUND:  Each year, the Office of Community Services (OCS), pursuant to Section 2608 of the LIHEAP statute, conducts compliance reviews of a sample of grantee programs.  These include both on-site and desk reviews.  Compliance reviews are an opportunity for OCS staff to see the variation in program design and implementation that exists among LIHEAP grantees.  With this variation comes much creativity, as grantees work to forge LIHEAP into a program that can meet the unique needs of the people and communities that they serve. 

PURPOSE:  OCS staff observed many best practices being performed by grantees during FY 2011 and 2012 compliance reviews.  What follows is our best effort to share these practices with all LIHEAP grantees, providing everyone an opportunity to learn from the ingenuity of their colleagues.

CONTENT:  In FY 2011, OCS conducted compliance reviews of LIHEAP in five States and two Tribes.  In FY 2012, compliance reviews were conducted in five States and five Tribes.  In FY 2013, OCS conducted compliance reviews in eight States and six Tribes.  Several noteworthy best practices were observed. 

Best Practice from the State of Alabama: Central Intake Systems

OCS is pleased to note that Alabama has successfully implemented a central intake database system that all subgrantees are required to use and which the grantee can access directly.  This direct access has resulted in improved efficiencies in monitoring subgrantees and investigating consumer complaints.  OCS is willing to hold a webinar for grantees to demonstrate their systems for other grantees to learn about, if there is sufficient interest in such a webinar.  For more information about its implementation, please contact Mr. Willie Whitehead at:  willie.whitehead@adeca.alabama.gov

Best Practice from the State of Alaska: Use of Fee Agents to Perform Intake for Clients Living in Geographically Remote Communities

The State of Alaska serves low-income clients living in very remote locations, often inaccessible by roads.  In order to ensure that they have equal access to LIHEAP services, Alaska hires and trains fee agents from those remote communities to help others complete and submit the LIHEAP application.  Fee agents are then compensated for every completed application that is submitted through their assistance.  Grantees wishing to duplicate this practice should ensure that a contractual agreement is in place between themselves and each fee agent, which spells out the rights and responsibilities of each party and the requirements to receive payment (such as a fully completed application with all relevant documentation).  Grantees should also ensure that they develop training and monitoring tools for fee agents prior to entering into agreements.  For more information about its implementation, please contact Ms. Susan Marshall at:  susan.marshall@alaska.gov

Best Practice from the State of Alaska: Strong Working Relationship with LIHEAP Tribal Grantees in Alaska

There are twelve directly-funded Tribes or Tribal Organizations within Alaska.  The State of Alaska has a very strong working relationship with all of these LIHEAP grantees.  Every quarter, all parties come together via teleconference to discuss emerging issues, difficulties in program administration, and brainstorm and share solutions to common challenges faced by all.  Such cooperation is an invaluable part of the way LIHEAP is operated in Alaska, by both the State and Tribes and Tribal Organizations. For more information about its implementation, please contact Ms. Susan Marshall at:  susan.marshall@alaska.gov

Best Practice from the Association of Village Council Presidents (AVCP): Use of Tribal Administrators to Certify Client Identity and Household Make-up

AVCP is a tribal consortium based in Bethel, Alaska that serves 37 remote villages in rural Southwestern Alaska.  As the majority of the villages in the consortium are not accessible by road, all LIHEAP applications are processed through the mail.  In order to certify client identity and household make-up, AVCP partners with the tribal administrator in each of their 37 villages.  Tribal administrators are asked to review and sign each LIHEAP application from their village, attesting to the identity of the client and the accuracy of the household count.  In this way, AVCP maintains strong LIHEAP program integrity without having face-to-face client interviews.  For more information about its implementation, please contact Mr. Nicholas Hoover at: nhoover@avcp.org

Best Practice from the State of Delaware: Use of Web-based Software to Digitize all Weatherization Client Files

The Delaware Department of Natural Resources and Environmental Control (DNREC) receives a portion of the State’s LIHEAP funds through an interagency transfer to administer the weatherization program.  This funding is combined with funds received from the Department of Energy and other non-federal funding streams.  DNREC has implemented the use of a web-based software that allows it to scan all weatherization files, which are then saved in a database as PDF documents.  DNREC is working to eventually completely eliminate the storage of paper files, shredding all documents after they are scanned into the database.  For more information about the specific software being used by DNREC’s weatherization program, contact Mr. Phil Cherry at: Philip.Cherry@state.de.us

Best Practice from the Narragansett Indian Tribe (NIT): Tracking Files Year After Year by Client Name for Small Client Populations

NIT serves a small client population of several hundred people in Rhode Island.  Overall, the same people tend to apply for LIHEAP services year after year.  LIHEAP staff at NIT track files by client name, using the same folder for the client’s application year after year.  When an existing client applies for LIHEAP, the Tribe already has the copies of their identification documents and social security cards.  Clients do not have to resubmit those documents every year, but only the pertinent income and utility information.  This significantly reduces the burden of the application process for the clients and simplifies record keeping for NIT. For more information about its implementation, please contact Mr. Parrish Noka at:  pnoka@nitribe.org

Best Practice from the State of Rhode Island: Use of Income Calculation Spreadsheet with Automated Formulas

The State of Rhode Island has developed a spreadsheet to help local agency staff calculate client income.  Staff simply enter the amounts of gross income listed on various sources of documentation and the spreadsheet uses automated formulas to calculate monthly, quarterly, and annual income.  This ensures that every single applicant has their income calculated in the same manner and greatly reduces calculation errors.  The template for this worksheet can be found in Attachment A.  For more information about its implementation, please contact Mr. Lewis Babbitt at: lewis.babbitt@dhs.ri.gov

Best Practice from the State of Rhode Island: Use of Spreadsheet-based Funds Tracking Report

The State of Rhode Island has developed a reporting mechanism for its grantees to report monthly expenditures by category, separating benefit payments, administration, weatherization materials, weatherization labor, training and technical assistance, etc.  This allows the State to track exactly how much funding has been spent in each category overall and ensure that administrative costs do not exceed 10% and weatherization does not exceed 15%.  It also allows grantees to break up administrative costs associated with energy payments and administrative costs associated with weatherization.  A separate report is used for each funding stream, providing local agencies the ability to distinguish between Department of Energy weatherization expenditures and LIHEAP weatherization expenditures.  This helps ensure that administrative costs accrued due to administration of LIHEAP-funded weatherization are not paid out of Department of Energy weatherization funds.  A template of this report can be found in Attachment B.  For more information about the structure and implementation of the report, please contact Mr. Lewis Babbitt at: lewis.babbitt@dhs.ri.gov

Best Practice from the Tanana Chiefs Conference (TCC): Establishing Strong Working Relationships with Local Bulk Fuel Vendors

TCC is a Tribal consortium serving the Alaskan interior region.  They serve villages spread out along a vast geographic area, many of which are not accessible by road.  Each village relies on one local bulk fuel vendor for heating fuel.  TCC has invested significant time in developing strong working relationships with all of their bulk fuel vendors.  For this reason, vendors will respond to crisis situations in their respective villages based on a simple commitment from TCC to send them payment on behalf of a client.  Thus, TCC is able to comply with the necessary timeframes for responding to crisis situations, without having to have a rushed payment process.  For more information about its implementation, please contact Ms. Anita Taylor at:  anita.taylor@tananachiefs.org

Best Practice from the Assiniboine and Sioux Tribes, and the Rosebud Sioux Tribe

These Tribes each operate a prepaid fuel program each year.  The Tribes contract for deliverable fuels in bulk at the beginning of the season, and draw against this reserve to issue benefits throughout the heating season.  This allows them to lock in a lower rate, insulate themselves from possible lack of competition in the fuel market, and make their benefit dollars go further.  The Tribes have accounting systems that ensure that they do not issue more fuel benefits than they have contracted for.  For more information about its implementation, please contact Ms. Sheila Spotted Bull with the Assiniboine and Sioux Tribes at sspottedbull@fortpecktribes.net and/or Ms. Eileen Shot with the Rosebud Sioux Tribe at eileenshot@yahoo.com .

ATTACHMENTS:  (A) Rhode Island’s Income Calculation Worksheet

                             (B) Rhode Island’s Financial Summary Report

INQUIRIES:   Lauren Christopher, Operations Branch Chief
                    Division of Energy Assistance
                    Telephone: (202) 401-4870
                    E-mail: lauren.christopher@acf.hhs.gov

Jeannie L. Chaffin
Office of Community Services