EXHIBIT H HEAF POLICIES PROCEDURES UPDATED 5-26-15.PDF

Exhibit H
Arizona Community Action Association
Home Energy Assistance Fund
SFY-2016
Policy Manual
July 1, 2015 – June 30, 2016

Table of Contents
Mission............................................................................................................................................. 1
Purpose and Principles .................................................................................................................. 1
Household Eligibility ...................................................................................................................... 1
An Eligible Applicant ................................................................................................................. 1
Relatives of Applicants ............................................................................................................... 1
Agency Employees or Other Employees of Sub-Contracted Entity, as Applicants .................... 1
Services to Native Americans Living on Reservation ................................................................ 2
Income Eligibility ....................................................................................................................... 2
Utility Status ............................................................................................................................... 2
Definition of Crisis ...................................................................................................................... 2
Sincere Effort to Pay ................................................................................................................... 2
Housing Status ............................................................................................................................ 2
Energy Burden ............................................................................................................................ 3
Grants Approvals ........................................................................................................................... 3
Grant Amounts ............................................................................................................................ 3
MPower® and Other Prepay Energy Sources ............................................................................. 3
Grant Frequency .......................................................................................................................... 4
Assistance Available ................................................................................................................... 4
Multiple Accounts ....................................................................................................................... 4
Grants pay for: ............................................................................................................................ 4
Account arrearages ................................................................................................................. 4
Security Deposit...................................................................................................................... 5
Current Account Charges ....................................................................................................... 5
Late Fees ................................................................................................................................. 5
Service Establishment and Reconnect Fees ............................................................................ 5
Decision Notice ........................................................................................................................... 5
Other Utility Assistance Programs .............................................................................................. 5
Payments Made to Ineligible Households ................................................................................... 5
Fraudulent Information ............................................................................................................... 5
Determining Household Income .................................................................................................... 5
Countable Income ....................................................................................................................... 5
Sources of countable income: ................................................................................................. 5
Excluded Income .................................................................................................................... 6
Individuals Whose Income Must Be Counted ............................................................................ 6
Individuals Whose Income Will Not Be Counted ....................................................................... 6
Household Members ................................................................................................................... 6
2015 – 2016 Federal Poverty Income Guidelines ....................................................................... 7
Determining Household Energy Burdens .................................................................................... 7
Verification and Documentation ................................................................................................... 8
Maintaining Client Records ........................................................................................................ 8
Policy Changes and Clarifications ................................................................................................ 8
Monitoring Process ..................................................................................................................... 9
Exhibit H HEAF Policies Procedures updated 5-26-15.doc 5/2015
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Cooperation ..................................................................................................................................... 9
Confidentiality ...................................................................................................................... 9
Non Discrimination Policy .................................................................................................... 9
Appeals Policy .................................................................................................................... 10
Glossary of Terms............................................................................................................... 11
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Mission
The Home Energy Assistance Fund develops and coordinates resources through education,
advocacy, financial assistance and partnerships to help Arizona families meet their basic
energy needs and move toward economic stability.
Purpose and Principles
The ACAA Home Energy Assistance Fund, also referred to as the “Fund”, has been established
to provide assistance to Arizona households needing assistance in managing their energy
burdens. The tenets of the program include:
 Crisis prevention – to guard against disconnection, to facilitate or to establish
reconnection of natural gas, electric services, and other non regulated fuel sources;
 Be an adjunct to currently existing energy assistance resources;
 Be a “hand up” not a “hand out”;
 Empower administering agencies with the discretion to assist families as needed.
Household Eligibility
An Eligible Applicant
The applicant must be an adult household member. The applicant must provide verification of
household membership. Verification includes but is not limited to: driver’s license with
household address, a post office marked document, or an authorized statement from a third party
such as a bank statement.
If the applicant is not a member of the household, in order to apply for assistance, s/he must show
evidence of a Power of Attorney or a notarized statement, or any other acceptable document
authorizing him/her to represent the household.
Relatives of Applicants
Intake workers are not permitted to complete applications for their own relatives to the first-
cousin level including step and in-law relatives. Specifically parents, siblings, spouses, aunts, and
uncles are to be interviewed by another intake worker, the Program Manager/Supervisor or
Director. Upon request, and when possible, Home Energy Assistance Fund staff may provide
application intake.
Agency Employees or Other Employees of Sub-Contracted Entity, as
Applicants
Agency employees and/or other employees of the sub-contracted entity shall not be denied the
right to apply for and receive services due to their employment with the sub-contracted entity.
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These individuals or members of their households may apply for assistance. Application intake
for an Agency employee must be conducted, eligibility determined, and authorized by the next
level of supervision. Upon special request, and if available, a Home Energy Assistance Fund
staff member may provide the intake of an application.
Services to Native Americans Living on Reservation
Agencies will provide Home Energy Assistance Fund bill assistance services to Native
Americans living on tribal reservations. The amount of funding to be used to serve families
living on reservation is to be no less than the proportion of all Native Americans living on
reservation within their respective service territory. Agencies are responsible for managing the
outreach and referral processes in order to serve this population.
Income Eligibility
Household income level will be limited to 200% FPIG1. Refer to the Determining Household
Income section of the Policy Manual for methods in determining the household income.
Utility Status
Applicants with a delinquent account2, a disconnect notice or who are without utility service are
eligible for assistance. Intake workers have the discretion to extend special consideration for
assistance to households demonstrating hardship and have a past due notice or a large outstanding
balance. Applicants are not required to be the customer or record but must provide verification of
the relationship between the utility services address and the applicant residential address.
Definition of Crisis
It is the intake worker’s responsibility to determine the crisis reason and its relationship to the
client’s current need for services. The crisis reason may be supported with the necessary
documentation and/or verification when applicable.
Crisis Reasons3:
1. Loss or reduction of income or public assistance benefits or delay in
receiving public assistance benefits.
2. Unexpected and/or unplanned expenses that caused lack of resources.
3. A condition that endangers the health and safety of the household.
Sincere Effort to Pay
Applicants are expected to have demonstrated an effort of payment over the prior 90 days, but it
is not required. There is no minimum dollar amount required to demonstrate effort of payment.
Housing Status
Assistance may be provided for individual residential utility accounts. Assistance may also be
granted if utilities are included with rent if proper verification is provided4.
1 Applicants over the 200% FPIG income guideline could qualify based on demonstration of need
2 An account that is one or more days past due and current charges are eligible
3 Refer to the Glossary of Terms for detailed examples of crisis reasons
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Energy Burden
The household Energy Burden will also be used to determine eligibility for a grant. The energy
Burden is determined by dividing the household’s one month utility costs by the last 30 days of
income. Refer to the Determining Energy Burden section of the Policy Manual for a detailed
process.
Grants Approvals
Grant Amounts
The total assistance possible is a maximum of $500. Payment(s) may include current and past
due amounts including late charges, deposits, and reestablishment fees.
M-Power® and Other Prepay Energy Sources
The energy burden for SRP M-Power® customers and other cash-based energy resources will be
the same as described in the Determining Energy Burden section. A history of purchases
from the vendor will be required to show purchases made in the past 30 days. The client
also may be required to present any purchase receipts that might fall between the usage statement
and the time of the application. Specific to SRP M-Power® customers, it will be important to
identify if the client has any debt on the account and what percentage of the purchases made have
been applied to the debt and applied to the forward balance to determine an accurate energy
burden.
The use of the funds, not to exceed $500, will be used to eliminate any debt on the account and
then to alleviate the crisis. The intake worker may determine the amount needed to sustain the
utility for the household until the next source of income or from an evaluation of the current
energy burden5. The intake worker may also take into consideration other past usage and the
weather at that time to determine the grant amount. It is important to communicate to the utility
vendor what portion of the grant will be applied to the debt and what portion will be applied to
the forward balance.
If the debt on the account exceeds $500, the forward balance and amount to pay off the debt can
be determined by working backwards. First determine the forward balance needed to alleviate
the crisis and then the remaining money available will be applied to the debt.
4 Evidence may include a copy of the lease or a note from the landlord.
5 Forward balance cannot not exceed 150% of the current energy burden.
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Example 1:
MPower customer
Back balance = $150
30 day need = $100
Payback percentage required by SRP: 40%
Total grant: $250
The case log must note that $150 is earmarked for balance payoff. Otherwise, the
$250 will automatically be posted with 60% going to purchase ($150) and 40%
going to payoff ($100), leaving $50 in arrears.
Example 2
Back balance = $700
30 day need = $120
Payback percentage: 40%
Total grant: $500
Case log should note that $120 goes to present purchase with remaining $320 to
be applied to back balance. Otherwise, the $500 will automatically be posted with
60% going to purchase ($300) and 40% going to payoff ($200).
Grant Frequency
A grant may be awarded to an eligible household one time per a 12 month period. The 12 month
period is based on the date of the last approved application. An applicant that was determined
ineligible may reapply at a later date.
Assistance Available
The Fund will pay for heating and cooling sources of: electric, gas, propane, oil, wood, coal, and
pellets. Assistance can also be provided to renters whose utilities are included in the rent and the
failure to make the rent payment threatens utility service.
Multiple Accounts
If a crisis is presented with more than one utility, the grant may be split between the account(s) in
crisis6.
Grants pay for:
Account arrearages
The grant amount cannot exceed the total amount owed on the account(s)7.
6 For example a gas and electric account
7 Exceptions may apply to clients with M-Power utility accounts
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Security Deposit
Security deposits will be made only in the name of the adult in the household.
Current Account Charges
Late Fees
Service Establishment and Reconnect Fees
Decision Notice
The Agency will provide written notice to the applicant of approval and/or denial of
assistance. The written notice may be hand delivered or mailed in English and/or Spanish. The
notice will provide grant amount(s) and/or reason for denial.
Other Utility Assistance Programs
When possible, the agencies are encouraged to access other sources of funding to alleviate the
crisis. The Fund also intends to reach households whose income falls outside of the boundaries
of more income-restricted funds such as LIHEAP. If necessary, the Fund may be combined with
other funding sources to prevent the crisis.
Payments Made to Ineligible Households
If assistance has been provided to an ineligible household due to; intake worker error, no funds
available when grant was promised, or the client was found ineligible after payment, the payment
guarantee will be honored and the intake agency will be responsible for repaying the award from
its agency funds other than Home Energy Assistance Fund monies. The Agency has the right to
appeal repayment to ACAA.
Fraudulent Information
If a client has been found to be fraudulent in his/her application and the payment has not been
sent to the utility, the payment will be stopped and the client appropriately informed.
Determining Household Income
Countable Income
All countable income for each household member will be considered in determining eligibility for
the Fund. The gross amount of countable income prior to deductions will be counted unless
otherwise specified. Income will be counted for the month that it was intended8. Income will be
included from the 30 days prior to the date of application.
Sources of countable income:
A. Earned Income: employment, self employment9
B. Benefit income: SSA, SSI, TANF-CA, VA, UI, GA,
8 A SSI check received on May 30 that is intended for the month of April will be counted as income in
April.
9 Net income will be counted (Gross income less business related expenses)
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C. Pensions
D. Worker’s Compensation
E. Child Support
F. Work Study
G. Other Unearned Income: rental income, and endowments or legal settlements.
H. Indian Gaming Commissions
Excluded Income
A. Food Stamps
B. Medicare
C. WIC
D. AmeriCorps Stipend
E. Earned income of a child that is 16 or 17 years of age and is a full time student
F. Earned income of a child under 16 years of age
G. Cash gifts
H. Insurance Payments
I. IDA Accounts
Individuals Whose Income Must Be Counted
Any income of a household member age 18 and older will be counted, including ineligible
household members. Income for all persons ages 16 and 17, who do not attend school full time,
will be counted.
Individuals Whose Income Will Not Be Counted
A. Income for persons ages 16 and 17 who attend school full time is not counted.
B. In cases of domestic violence, the income and resources of the abuser are not counted as
long as the client does not have access to his/her income and resources, or the abuser’s
income and resources.
Household Members
Each person living in the home is considered a household member. Income and eligibility will be
determined based on the entire household. Exceptions to household members are “boarders”10.
Roommates’ income is treated as one household entity 11. Refer to the Glossary for detail
explanations of ‘boarders’ and ‘roommates’.
10 Boarders are one or more persons living in the same house paying rent to the owner of the home who
also lives in the same house. Income of the owner of the home and the boarder is not treated as one
household. Boarders cannot be related by blood or law.
11 Roommates are one or more persons living in the same house paying rent to the landlord outside of the
home. Income for each roommate is included as the household income as one entity.
Exhibit H HEAF Policies Procedures updated 5-26-15.doc 5/2015
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2015– 2016 Federal Poverty Income Guidelines
Effective July 1, 2015 – June 30, 2016
Federal Poverty Income Guidelines - Monthly
Allowable Household Income
Percent of Poverty
Household size 150% 200%
1 $1,471 $1,962
2 $1,991 $2,655
3 $2,511 $3,348
4 $3,031 $4,042
5 $3,551 $4,735
6 $4,071 $5,428
7 $4,591 $6,122
8 $5,111 $6,815
For each additional $520 $693
member add:
Determining Household Energy Burdens
Energy Burden is determined by dividing the household’s one-month utility costs by the last 30
days of income.
Example:
Past 30 days of household income: $1,000
One-month current electric bill: $45, one-month current gas bill: $50 = $95
$95/$1,000 = 9.5% Energy Burden
If the applicant has more than one utility source, all utility source costs will be combined to
determine the energy burden even though the applicant may only present a crisis on one account.
In case the current utility cost cannot be obtained, a standard cost of $200 will be substituted in
determining the energy burden. For electric and gas, a current one month bill can be obtained by
calling the utility company.
An energy burden for non-regulated fuel sources such as wood, oil, coal and pellets can be
determined by figuring the cost of the fuel from two consecutive purchase receipts. The 30 day
fuel cost can be determined by dividing the total cost of the first purchase by the number of days
between the first and the second purchases. If the fuel cost cannot be obtained, a standard cost of
$200 may be substituted.
Example:
Propane receipt 1 dated 1/10/07
Cost: $300
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Quantity: 100 gallons
Propane receipt 2 dated 4/10/07
Cost: $250
Quantity: 100 gallons
Date of Application: 7/10/07
Cost per day = $300 / 90 days = $3.33
30 day energy cost = $3.33 * 30 = $99.99
Household income: $1,000
30 day energy cost: $99.99
$99.99/$1,000 = 9.9% Energy Burden
When an applicant’s rent includes the utility cost and that cost is not specified in the lease
agreement, a $200 standard cost will be used in determining the energy burden. To demonstrate
crisis, the renter must provide evidence of delinquent rent through a notice from the landlord.
The intake worker must receive assurance from the landlord that the renter will not be evicted and
that the grant will be applied appropriately to the renter’s account.
Verification and Documentation
The applicant has the primary responsibility for providing all required verification. In situations
where it is difficult for the applicant to obtain verification needed to complete the eligibility
determination, the partnering agency will offer assistance in obtaining the verification.
Depending on funding source, there may be different eligibility guidelines.
For the Home Energy Assistance Fund Program and the Utility, Repair, Replacement, and
Deposit Program only, please utilize the following exhibit (attached to your contract):
Verifying Citizenship and Non-Citizen Legal Permanent Resident Status. This is attached
for further guidance on determining applicant’s citizen and non-citizen status.
Maintaining Client Records
The partnering agency is required to maintain supporting financial records, documentation and
statistical records for three (3) years.
Policy Changes and Clarifications
Revisions to any policies and procedures will be reviewed and approved by the ACAA Home
Energy Assistance Fund Advisory Board and the ACAA Board of Directors. All revisions will be
sent to administering agencies to update their manuals. As revisions are received it will be the
staff’s responsibility to update their copy of the Home Energy Assistance Fund Policy Manual.
Issues regarding policy and/or procedures must be submitted in writing.
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Monitoring Process
The Agency will be responsible for ensuring that the Fund policies and procedures are being
followed. The Home Energy Assistance Fund staff will conduct application and case file reviews
during monitoring visits.
Cooperation
Applicants must cooperate in all aspects of the application process. Applicants must provide
requested information or verification and complete and sign an application. If the applicant
refuses, the application will be denied. The partnering agency should document the lack of
cooperation by the applicant for proper notation in refusal of assistance.
Confidentiality
Public law and federal regulations place restrictions on the release of confidential information,
and set guidelines for the disclosure of non-confidential materials. All applications, records, files
and communications of the Fund and its partners, relating to specific applicants for assistance and
recipients of services funded by the Fund, are confidential records.
All information, regarding an applicant or recipient, is confidential and may be disclosed only for
purposes of determining eligibility, providing services, or investigating suspected fraud in
connection with the program. Applicants authorize access to their records by signing the
application. Anyone not authorized on the application must have the applicant's written approval
to access information.
Information that can be exchanged must pertain to the eligibility of the applicant, and excludes
items that do not address eligibility, i.e., personal details. Inappropriate disclosure of information
can result in severe disciplinary action, or could result in the suspension of the partnering
agreement.
Access to information by inappropriate, unauthorized individuals or parties shall be considered a
violation of the individual's right to confidentiality. Care should be taken to secure all files in the
office so that unauthorized personnel do not have access to them. All records shall be open to
any and all federal, state, and contractor auditors and/or examiners in the course of their regular
audits.
General information, policy statements, or statistical materials which cannot be directly identified
with any individual or family are not considered confidential. They may be given to, or provided
by: agencies, helping organizations, or contracted parties, unless restricted by Arizona statutes,
federal regulations, or court orders.
Non Discrimination Policy
In compliance with Title VI of the Civil Rights Act of 1964 and Executive Order 12250, no
individual in Arizona shall be excluded from participation in, denied benefits or subjected to
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discrimination under any program or activity receiving Federal funds, because of: race, color,
national origin, handicap, religion, or sex.
In compliance with the Age Discrimination Act of 1975, no individual shall be denied services or
participation or be subjected to discrimination in any of its programs or activities on the basis of
age.
Appeals Policy
The client/agency has the right to appeal a denial of assistance or an awarded grant amount.
Appeals by the client will follow the policies of the intake partner agency and will be addressed
by the Home Energy Assistance Fund administrative staff.
Complaints regarding the service of the administering agency, discrimination or other issues
directly related with the administering agency and staff must be addressed to the office where the
application was made.
Exhibit H HEAF Policies Procedures updated 5-26-15.doc 5/2015
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Glossary of Terms
Standard Cost
The default cost associated with the utility consumption when the actual cost is not feasible.
Boarder
Boarders are one or more persons living in the same house paying rent to the owner of the home
who also lives in the house or one who lives and pays rent in a commercial boarding house.
Income of neither the owner of the home nor other boarders is not counted jointly. Boarders
cannot be related by blood or law to the owner of the home.
Example:
Susan and Jane live in the house that Susan owns. There is no blood or law relationship.
Susan is renting a room to Jane and her two children. Jane and her two children are the
boarders. Susan and Jane’s income will be counted separately.
Crisis Reasons
1. Loss of income, public assistance benefits or delay in receiving public assistance.
Examples may include but are not limited to: loss of employment, theft of income, serious
illness which causes a loss of income, divorce, abandonment or death of wage earner,
reduction of benefits or public assistance monies.
2. Unexpected or unplanned expenses. Examples may include by are not limited to: car
repairs, medical bills, natural or man-made disasters, death in immediate family, court fines
of a minor child.
3. A condition that endangers the health and safety of the household. Examples may
include but are not limited to: lead poisoning, condemned property, infestation, domestic
violence, asbestos, medical condition that require utility service to operate life-saving
equipment such as oxygen machines, heart monitors, breathing machines, etc.
Customer of Record
The name of the person on the utility account.
Delinquent Account
An account that is one or more days past due.
Household
Consists of each person living in the home at the time of application.
Late Fees
Charges imposed by the utility company to the account due to a tardy payment to the account.
Power of Attorney
A legal document authorizing one person to act on behalf of another.
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Roommates
Roommates are one or more persons living in the same house paying rent to a landlord living
outside of the home. The income for each roommate is counted as the household income.
Examples:
Linda and Donna are roommates. Donna pays rent to Linda, who has a rental agreement with
a landlord living outside the home. They will be considered roommates and their income will
be counted jointly.
Jane and her new baby live with her Aunt Betty. Jane no longer receives child support and
cannot pay her Aunt any rent money for the month of June. Because they are related, Jane is
considered a roommate. Jane and Betty’s income will be counted jointly.
Service Reestablishment Fees and Reconnection Fees
Charges assessed by the utility company to reestablish/reconnect service following a service
disconnection due to nonpayment.
Exhibit H HEAF Policies Procedures updated 5-26-15.doc 5/2015
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