Linking LIHEAP with Ratepayer

Linking LIHEAP with Ratepayer-Funded Programs

To determine program integration, it is necessary to identify those points where program linkages can occur with the existing energy assistance and/or weatherization program. A linkage occurs when there is an overlap between programs. For example, a system benefits charge program uses the same eligibility criteria, or uses the same local organizations to do outreach and intake. To identify those points of overlap, those linkages, tables are set forth below for ten states (Illinois, Maine, Maryland, Massachusetts, New Hampshire, Ohio, Oregon, Pennsylvania, Texas, Wisconsin).

The points of overlap tracked in the tables below were developed in a LIHEAP symposium attended by various state program directors, technical consultants, and other administrators of low-income energy assistance programs. The final report from that symposium is set forth in Appendix B.

Reading the Tables

In general there is no right or wrong approach to linkages and integration. Clearly, however, a state with lots of no's or yes's in their respective table indicates a consistency of approach.

A close up of Ohio, for example, reveals that it has 18 yes's and 9 nos. It has consistent linkage on oversight, delivery and administration. That may be because the Ohio LIHEAP and weatherization programs are under the same department administratively. This has transferred through to the public benefits administration. Interestingly, the Ohio Department of Development (DOD), which operates LIHEAP in Ohio, was represented in the pre-restructuring legislative debate, which helped get the LIHEAP/WAP administering agency named the administrator of the public benefits fund as well.

By contrast, Pennsylvania has virtually no linkages on the funding, oversight, delivery or administration front. Historically, utilities have operated low-income programs in Pennsylvania with oversight by the state PUC. The departments that handle LIHEAP and weatherization are separate and community action agencies are not involved in LIHEAP administration, although some are involved in weatherization administration. In an order implementing the state's universal service programs, the PUC said that that utilities themselves should continue to administer their programs, while relying on community-based organizations to the extent practicable for actual program delivery.

The Data in the Tables

The data in the attached tables was obtained through interviews with LIHEAP administrators as well as a review of the operating documents of programs funded through system benefit charge revenues. Program linkages (or lack of linkages) were examined in each of the following program areas:

Funding: Funding examines the direct dollars of benefit applied to customer accounts. A LIHEAP cash or crisis benefit is a direct dollar of benefit. A dollar of rate discount is a direct dollar of benefit.

Oversight: Oversight has four different components: (1) oversight of day-to-day program operation; (2) periodic program monitoring on such things as participation levels, expenditures, and turn-over; (3) program impact and process evaluation; and (4) fiscal auditing.

Administration: Program administration involves program design and implementation.

Outreach: Program outreach involves the provision of program information to potential participants and the solicitation of program participation.

Delivery: Program delivery involves the actual interface between the low-income customer and the program. Program delivery can involve program intake, energy efficiency audits, conservation education, budget counseling, and the like.

Linkages can occur in one or more of the above program areas. Linkages in one area do not necessarily imply that there are linkages in other program areas (let alone in all areas).

The following table is a summary table. Please see individual states for important explanatory notes.

		Linkages Between LIHEAP and Ratepayer-Funded Energy Assistance Programs

		Illinois	Maine	Maryland	Massachusetts	New Hampshire	Ohio	Oregon	Pennsylvania	Texas	Wisconsin
ALIGN="LEFT">Funding
1	Do annual SBC dollars directly go up/down based on the level of LIHEAP dollars?	No	No	No	No	No	No	No	No	No	Yes
2	Do SBC benefit levels directly go up/down based on the LIHEAP benefit provided?	No	No	No	No	No	Yes	No	No	No	No
3	Does LIHEAP/WAP determine the allocation between program components?	Yes	N/A	Yes	No	No	Yes	No	No	No	No
4	Do LIHEAP benefits go up/down depending on the level of the SBC benefit.?	No	No	No	No	Yes	No	No	No	No	No
Oversight
1	Does LIHEAP/WAP set the size of the overall budget?	No	No	No	No	No	Yes	No	No	No	No
2	Does LIHEAP do the program evaluation for SBC expenditures?	Yes	Yes	Yes	No	Yes	Yes	Yes	No	Yes	Yes
3	Does the LIHEAP office audit whether utilities make correct SBC payments?	No	Yes	No	No	No	Yes	No	No	No	No
4	Does LIHEAP provide the daily staffing for SBC program administration?	Yes	Yes	Yes	No	Yes	Yes	Yes	No	No	Yes
5	Does LIHEAP do data collection on SBC recipients?	Yes	Yes	Yes	No	No	Yes	Yes	No	Yes	Yes
Administration
1	Are there explicit differences in SBC and LIHEAP eligibility?	No	No	No	Yes	Changes	No	No	Yes	Maybe	No
2	Are there explicit differences in the energy bill paid by SBC and LIHEAP?	No	Yes	Yes	Some	Yes	Yes	No	Some	No	Yes
3	Does LIHEAP set the amount of the SBC benefit?	Yes	No	Yes	No	No	No.	Yes	No	No	Yes
4	Does LIHEAP/WAP promulgate SBC program rules?	Yes	No	Yes	No	Yes	Yes	Yes	No	Yes	Yes
5	Does LIHEAP provide the computer connection between utilities and the SBC program?	Yes	Yes	Yes	No	Yes	Yes	Yes	No	None	Yes
6	Is SBC administration centralized at the state level?	Yes	No	Yes	No	Yes	Yes	Yes	No	Yes	Yes
Outreach
1	Does receiving LIHEAP automatically enroll a consumer to receive SBC?	Yes	Yes	No	Yes	Yes	Yes	No	No	Yes	Yes
2	Can a household receive SBC without receiving LIHEAP?	No	No	Yes	Yes	Yes	No	Yes	Yes	Yes	Yes
3	Are there explicit differences in the target population for SBC and LIHEAP?	No	No	Yes	No	No	Yes	Yes	Yes	No	No
4	Does LIHEAP provide consumer outreach unique to the SBC program?	Yes	Yes	Yes	No	Yes	Yes	No	No	Not Applicable	No
Delivery
1	Do all SBC recipients also receive LIHEAP?	Yes	No	No	No	No	Yes	No	No	No	Yes
2	All application forms for LIHEAP and SBC the same (WAP and SBC)?	Yes	No	No	No	No	Yes	Yes	No	No	Yes
3	Are time periods within which consumers may apply for LIHEAP and SBC the same?	Yes	Yes	No	No	No	No	Yes	No	No	Yes
4	Are intake agencies identical for SBC and LIHEAP?	Yes	Yes	Yes	Yes	Yes	Yes	Yes	No	No	Yes
5	Do LIHEAP pay SBC benefits directly to the consumer or to utility on consumer's behalf?	Yes	Yes	No	No	No	No	Yes	No	No	Yes
6	Does LIHEAP provide notices of the need for periodic income recertification?	Yes	Yes	Yes	No	Yes	Yes	Yes	No	No	Yes

Important Note: This is a summary table. Please see individual states for important explanatory notes.

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