Home Energy Assistance Program Vendor Training - Program Year 2019 MaineHousing Energy & Housing Services September – October 2018

HEAP Program Team Kathy Kinch, Manager of HEAP and Financial Reporting Lori McPherson, Vendor Compliance Officer Emily Morang, Vendor Compliance Officer Laura James, HEAP Program Officer Kyme Ferenc, Fair Hearing and Fraud Officer Vanessa Taylor, Fair Hearing and Fraud Officer

11/13/2018 Training Objectives General knowledge of HEAP and TANF Supplemental Benefits Understand terms and conditions of Vendor Agreement How to complete Annual Consumption Reports Get vendor feedback on new database 2015/2016 Vendor Training

Agenda Overview

Training Materials and Resources

Vendor Web Portal

HEAP Grant

Intent of HEAP Help income-eligible Households with their home energy costs Not designed to pay Household’s total heating costs

PY 2018 HEAP Benefits Households = 29,549 Average benefit = $826 Lowest benefit = $160 (high income, low consumption) Highest benefit = $2,714 (low income, high consumption)

PY 2018 HEAP Benefits - $24.4M

Program Components Fuel Assistance (HEAP) Energy Crisis Intervention Program (ECIP) Central Heating Improvement Program (CHIP) Weatherization Assurance 16 (case management to help HEAP clients manage and reduce energy cost)

Federally Funded Administered by Health & Human Services Grant period Oct 1 – Sept 30 (FFY) Governed by LIHEAP Statute (law passed by Congress)

State Guidelines Consistent with federal requirements State rulemaking HEAP Rule – Chapter 24 State Plan - grant application Vendor Handbook

Annual Public Hearings – June HEAP Rule – Chapter 24 HEAP State Plan (grant application) Vendors are encouraged to participate in the public hearing process.

How does funding flow? President submits budget Congress approves budget Funds allocated to federal agencies (HHS) Funds allocated to States (October / November)

Application Period HEAP Fuel Assistance Aug 27, 2018 thru Jul 15, 2019 Energy Crisis Intervention Program Nov 1, 2018 thru Apr 30, 2019

11/13/2018 Use of Benefits 2015/2016 Vendor Training

Home Energy Types Oil & Kerosene Propane Electricity & Natural Gas 11/13/2018 Home Energy Types Oil & Kerosene Propane Electricity & Natural Gas Wood/Corn Pellets, Bio-Bricks & Coal Firewood 2015/2016 Vendor Training

11/13/2018 Use of Benefits Must be consistent with Vendor Voucher Report or Credit Notification Report, which identifies the approved: Home Energy type Physical Address (service location) Account Information 2015/2016 Vendor Training

Contact MaineHousing If there is a question about fuel type, delivery address, or account information listed on Vendor Voucher or Credit Notification Report.

11/13/2018 Approval Required Any deviations from Vendor Voucher Report or Credit Notification Report must be approved in writing by MaineHousing. 2015/2016 Vendor Training

11/13/2018 Notify MaineHousing Client has remaining HEAP funds on account and moves to new service location MaineHousing must authorize use of Benefits for new service location 2015/2016 Vendor Training

Kerosene vs. Oil If Vendor Voucher Report or Credit Notification Report lists kerosene as approved fuel type, Benefits cannot be used for oil (even if client requests oil).

Contact MaineHousing if: Oil listed on VVR or CNR Vendor knows tank is located outside

Delivery Options Vendor may deliver entire benefit amount even if client orders smaller amount, unless: All Household members are moving Heating System has mechanical difficulties Storage tank or hopper is being replaced or not up to code

Cannot be used for downside protection fees 11/13/2018 HEAP Benefits may be applied to price protection plans. Cannot be used for downside protection fees 2015/2016 Vendor Training

Cannot be used for: Delivery fees (except ECIP) August 23-24, 2017 Cannot be used for: Delivery fees (except ECIP) Hazmat or fuel recovery fees Late fees Clean and repair service charges Security deposits PY 2018 HEAP Training

Benefits Expire Program Year Must use by: Cannot use on or after: 2018 11/13/2018 Benefits Expire Program Year Must use by: Cannot use on or after: 2018 Apr 30, 2019 May 1, 2019 (12:00 am) 2019 Apr 30, 2020 May 1, 2020 (12:00 am) 2015/2016 Vendor Training

Benefits for any Program Year prior to PY 2018 have expired. 11/13/2018 Benefits for any Program Year prior to PY 2018 have expired. Return these funds to MaineHousing immediately. 2015/2016 Vendor Training

Quiz - Use of Benefits Handouts Tab – Page 1

Applying Benefits Retroactively to October 1 11/13/2018 Applying Benefits Retroactively to October 1 2015/2016 Vendor Training

Optional – not mandatory 11/13/2018 HEAP and TANF Supplemental Benefits may be applied to eligible deliveries back to October 1. Optional – not mandatory 2015/2016 Vendor Training

What is an eligible delivery? Deliveries made on or after Oct 1 Deliveries paid or unpaid by client for approved Home Energy type

Ineligible Deliveries 11/13/2018 Ineligible Deliveries Non-approved Home Energy types Deliveries paid by towns, General Assistance, or organizations 2015/2016 Vendor Training

Advantages of going back to October 1 11/13/2018 Advantages of going back to October 1 Remember: it is optional 2015/2016 Vendor Training

Funds become “client funds” 11/13/2018 Funds become “client funds” HEAP rules do not apply to “client funds” “Client funds” can be applied to outstanding balances for service or ineligible deliveries 2015/2016 Vendor Training

Reduces volume of Benefit Returns due to: 11/13/2018 Reduces volume of Benefit Returns due to: Client changes moves, deceases, requests another vendor Benefit expiration 2015/2016 Vendor Training

Documenting Transactions Effective for PY 2019 Benefits Retroactive use of Benefits is allowed only if Vendor’s records document the transaction details associated with applying Benefits to prior deliveries.

Documenting Transactions Identify amount of any remaining HEAP Date of delivery being covered DOR adjustment (if applicable) Handbook – Section 6, page 9

Recap Benefits may be applied to: 11/13/2018 Recap Benefits may be applied to: Eligible deliveries - October 1 forward Approved fuel type listed on VVR or CNR Client paid or unpaid deliveries 2015/2016 Vendor Training

Oil/Kerosene Pricing

Oil / Kerosene Pricing Discount Off Retail = $0.07 per gallon Applies to oil or kerosene, whichever is listed on Vendor Voucher Report Applies to HEAP gallons only

Oil / Kerosene Pricing DOR does not apply to gallons paid by TANF Supplemental if delivery occurred on or after 9/1/18 TANF Supplemental and ECIP pricing must be based on vendor’s cash price not charge price

DOR and Vendor Discount Programs If HEAP client is eligible for discount which is greater than $0.07 DOR, Vendor must give the greater discount on gallons paid by HEAP.

DOR and Vendor Discount Programs Charge Price Retail Cash Price DOR Price Discount Rate Required HEAP Price $2.62 $2.42 $2.35 Veteran $2.22 (Veteran) Senior $2.37 (DOR)

Pricing Other Fuel Types

Price cannot be based on charge price Maximum Price Per Unit For units paid by HEAP, TANF Supplemental or ECIP, price per unit cannot be greater than vendor’s daily cash price. Price cannot be based on charge price

Pricing Quiz Handouts Tab - Page 2

TANF Supplemental Benefits August 23-24, 2017 TANF Supplemental Benefits PY 2018 HEAP Training

TANF Supplemental Benefits State of Maine DHHS provides up to $3M annually in TANF funds to MaineHousing. Funds must be used to provide supplemental fuel assistance to HEAP- eligible families with children.

Who is eligible? Household will be eligible for TANF Supplemental Benefits if Household: Received current Program Year HEAP benefit Has member under age of 18 Does not reside in Subsidized Housing with heat included

PY 2018 TANF Supplemental Eligible Households = 5,905 Credits Issued = $1.77M ($300 per Household) Payments Issued = $728K (thru 9/14/18) Outstanding Credits = $1.04M (must be used by April 30, 2019)

Guarantees payment post delivery Credit Notification Report Guarantees payment post delivery Issued third Friday of month following the issuance of Household’s HEAP Benefit

Credit Notification Report Handouts Tab - Page 17

PY 2019 Schedule (tentative) Households eligible for TANF Supplemental Benefits will be identified and processed on a monthly basis. HEAP benefit issued: CNR issued to vendor: On or before Dec 31, 2018 Jan 18, 2019 Jan 1 to 31, 2019 Feb 15, 2019 On or after Feb 1, 2019 Third Friday of the month following issuance of the HEAP benefit

Sample letter – Handouts, Page 3 How are clients notified? MaineHousing mails benefit notification letters three business days after issuing/mailing CNR to vendor. Sample letter – Handouts, Page 3

Vendor Pricing TANF Supplemental pricing must be based on vendor’s cash price not charge price Oil/kerosene: DOR does not apply to gallons paid by TANF Supplemental if delivery occurred on or after 9/1/18

Order of priority for using benefits PY 2018 HEAP PY 2018 TANF Supplemental PY 2019 HEAP PY 2019 TANF Supplemental

Post Delivery Payment Metered delivery ticket – oil/kerosene and propane Invoice – all other fuel types Transaction report showing delivery/purchase and payment activity from previous May 1 through date of delivery being invoiced

Oil, Kerosene and Propane If amount on delivery ticket is greater than amount billed to TANF Supplemental, notate ticket with dollar amounts paid by: TANF Supplemental HEAP (if applicable) Client or third-party (if applicable) Sign and date ticket

Post Delivery Payment MaineHousing reviews vendor’s documentation to validate HEAP benefits have been exhausted and appropriately used. TANF Supplemental payment issued within 10 business days of receipt and approval of documentation

Annual Consumption Report Units paid by TANF Supplemental - include in “Total Household Gal/kWh” and “Total Household Cost” columns only Do not include TANF Supplemental units in “LIHEAP Gal/kWh” column

TANF Supplemental Benefits Questions about TANF Supplemental Benefits Contact MaineHousing

Recordkeeping

Detailed records are required to: Fully account for use of federal dollars Support federal reporting requirements, including Annual Consumption Reports

Documentation Requirements Delivery tickets (dated and metered) Daily Cash Price Log Wood/Corn Pellets or Bio-Bricks: invoices for pickups and deliveries Price protection plans (signed)

Metered Delivery Ticket Customer name Delivery address Date of delivery Type of fuel delivered Units delivered Price per unit Total

Manual Transaction Record If Vendor chooses to maintain HEAP account records manually, you may use MaineHousing’s Manual Transaction Report Form.

Section 9 - Recordkeeping All records for benefit transactions that occurred during contract term must be retained for 3 years after agreement expiration date. Vendor Agreement Term Disposal Date 7/1/2014 to 6/30/2015 7/1/2018 7/1/2015 to 9/30/2016 10/1/2019 10/1/2016 to 6/30/2017 7/1/2020

Let’s look at some delivery tickets Handouts Tab – Page 4

HEAP Client Account Records Name and address All posted transactions for Home Energy purchases paid (or unpaid) by HEAP, TANF Supplemental, ECIP, client, or another party Amount of any remaining HEAP balance

All federal funds must be fully accounted for Posting Transactions Do not adjust units, price per unit, or total delivery cost to “zero out” small HEAP credit balances Do not write-off or absorb small HEAP credit balances All federal funds must be fully accounted for

Incorrect postings examples Handout Tabs – Page 7

Annual Consumption Report (ACR)

Purpose of ACR Account for use of HEAP & ECIP funds Determine household’s heating costs Comply with federal reporting requirements

Performance Data Report

Total fuel costs reported on ACR used to determine household benefits for following Heating Season

Annual Consumption Report 11/13/2018 Overview Annual Consumption Report 2015/2016 Vendor Training

ACR Reporting Period Capture all deliveries and use of benefits from May 1, 2018 thru April 30, 2019

LIHEAP Gallons/Units Program Year Deliveries made on or after: PY 2018 May 1, 2018 PY 2019 Oct. 1, 2018

Annual Consumption Report 11/13/2018 Annual Consumption Report Let’s work through examples 2015/2016 Vendor Training

HEAP Benefit Remaining Betty Baker 546 HEAP Benefit Remaining HEAP Benefit $640.00 2/21/19 Delivery - $234.90 3/25/19 Delivery Benefit Remaining $170.20 HEAP Units 2/21/19 Delivery 1 ton 3/25/19 Delivery + 1 ton 2 ton

Betty Baker 546 Total HH Units Delivery 2/21/19 1 ton Delivery 3/25/19 Total HH Cost Delivery 2/21/19 $234.90 Delivery 3/25/19 + $234.90 $469.80

Eve Harvey 471 HEAP Benefit Remaining Prior Year Benefit Remaining $460.96 8/27/18 Delivery - $134.95 10/15/18 Delivery HEAP Benefit + $600.00 11/27/18 Delivery 12/30/18 Delivery - $136.45 1/24/19 Delivery - $209.93 2/22/19 Delivery - $138.95 4/2/19 Delivery $34.33

Eve Harvey 471 HEAP Gallons 8/27/18 Delivery 50.0 10/15/18 Delivery + 50.0 11/27/18 Delivery 12/30/18 Delivery 1/24/19 Delivery + 75.0 2/22/19 Delivery 4/2/19 Delivery 375.0

Eve Harvey 471 Total HH Gallons 8/27/18 Delivery 50.0 + 50.0 11/27/18 Delivery 12/30/18 Delivery 1/24/19 Delivery + 75.0 2/22/19 Delivery 4/2/19 Delivery 375.0

Eve Harvey 471 Total HH Cost 8/27/18 Delivery $134.95 + $134.95 11/27/18 Delivery 12/30/18 Delivery + $136.45 1/24/19 Delivery + $209.93 2/22/19 Delivery + $138.95 4/2/19 Delivery $1,026.63

Prior Year Benefit Remaining Kim Morin 213 Prior Year Benefit Remaining Prior Year HEAP Benefit $638.00 1/17/18 Delivery - $239.90 4/26/18 Delivery - $237.90 $160.20 Benefit Remaining Prior Year Benefit Remaining $160.20 HEAP Benefit + 488.00 1/22/19 Delivery - $239.90 $408.30

Kim Morin 213 HEAP Gallons 1/22/19 Delivery 100.0 Total HH Gallons Total HH Cost 1/22/19 Delivery $239.90

HEAP Benefit Remaining Harold Porter 7669 HEAP Benefit Remaining HEAP Benefit $974.00 11/23/18 Delivery - $281.90 12/30/18 Delivery - $579.40 2/28/19 Delivery -$287.90 Benefit Remaining $0.00 HEAP Gallons 11/23/18 Delivery 100.00 12/30/18 Delivery +200.00 2/28/19 Delivery +39.15 339.15

Harold Porter 7669 Total HH Gallons 10/4/18 Delivery 100.0 + 100.0 112/30/18 Delivery + 200.0 2/28/19 Delivery 4/6/19 Delivery +103.2 603.2

Harold Porter 7669 Total HH Cost 10/4/18 Delivery $279.90 + $281.90 12/30/18 Delivery + $579.40 2/28/19 Delivery + $287.90 4/6/19 Delivery + $300.21 $1,729.31

Benefits and Payments

Benefit amount is based on: 11/13/2018 Benefit amount is based on: Number persons living in dwelling Household income Fuel consumption for primary Heating System 2015/2016 Vendor Training

Primary Applicant Selects Vendor at time of application 11/13/2018 Primary Applicant Selects Vendor at time of application May choose to have Benefit issued for secondary Heating System 2015/2016 Vendor Training

Payment Options Vendor selects form of payment on Vendor Agreement Check Direct deposit (wire transfer)

MaineHousing issues payments weekly Tue-Wed Initiate payment process Thursday Mail checks & Voucher Reports Initiate wire transfer Friday Direct deposit Vendor’s account

Let’s look at the letter Following Tuesday CAA mails Benefit Notification letters to clients whose HEAP benefits were issued the prior week Let’s look at the letter Handout Tab – Page 12

Vendor Voucher Report (VVR) Primary Applicant’s name & phone number Delivery address Benefit amount Home Energy type Account info CAP code Payment memo

Vendor Voucher Report Examples

Contact MaineHousing if: Vendor Voucher Report does not match your records You suspect there has been a duplicate payment made for a client

Benefits paid by manual checks Reissuing Benefits from prior Program Year (example: client changed vendors) Returning vendor or client funds that were sent to MaineHousing in error

Manual Checks Handouts Tab – Page 16 Vendor will not receive Vendor Voucher Report with manual check Check stub provides important information Handouts Tab – Page 16

Questions about Payments or Vendor Voucher Reports: Contact MaineHousing

Benefit Returns

What is a Benefit Return? Return of unused HEAP funds on Household’s account with fuel vendor How is the return initiated? CAA, MaineHousing, or Vendor completes Benefit Return Form

Benefits must be returned if: CAA or MaineHousing requests return Account inactive 12 consecutive months Not used by April 30 of second program year

Benefits must be returned if: Sole member of Household is deceased Client moves out of delivery area Client terminates account with Vendor Termination of Vendor Agreement

Required Documentation Benefit Return Form (see instructions in Handbook) Detailed transaction report – May 1 forward Example: PY 2019 transaction history from May 1, 2018 to current

Benefit Returns Return funds within 15 calendar days Repeated disregard of Benefit Returns may be result in: MaineHousing audit Placement on Watch List Termination

Questions about a request? Contact: Community Action Agency who that issued request MaineHousing

Expired Benefits Sweeping Accounts

Benefits Expire Program Year Must use by: Cannot use on or after: 2018 11/13/2018 Benefits Expire Program Year Must use by: Cannot use on or after: 2018 Apr 30, 2019 May 1, 2019 (12:00 am) 2019 Apr 30, 2020 May 1, 2020 (12:00 am) 2015/2016 Vendor Training

Benefits for any Program Year prior to PY 2018 have expired. 11/13/2018 Benefits for any Program Year prior to PY 2018 have expired. Return these funds to MaineHousing immediately. 2015/2016 Vendor Training

Sweep Accounts in May Return expired funds by June 30 Submit Benefit Return Form for each client or spreadsheet for multiple clients (Handouts Tab – Page 18) Provide transaction report for each client

Reminders Return funds within 15 calendar days Provide contact person name Identify correct Program Year

Energy Crisis Intervention Program

11/13/2018 Purpose Avert Energy or Life Threatening Crisis (November 1 thru April 30) 2015/2016 HEAP Training

Allowable Measures Home Energy deliveries Utility disconnects Minor Heating System repairs

PY 2018 ECIP Benefits Fuel Deliveries = 2,872 Households Total Benefits = $820,186 Repairs = 27 Households Total Benefits = $7,680 Utility Disconnects = 62 Households Total Benefits = $15,399

No heat or risk of losing heat 11/13/2018 Household may be eligible if: No heat or risk of losing heat ≤ 1/8 tank of oil/kerosene ≤ 25% in propane tank ≤ 3-day supply of Home Energy 2015/2016 Vendor Training

Facing a heating crisis due to Heating System malfunction 11/13/2018 Household may be eligible if: Facing a heating crisis due to Heating System malfunction ECIP can cover repairs if authorized by CAA purchase order 2015/2016 Vendor Training

Crisis must be averted within 48 hours Energy Crisis Has Heating System or Heating Source that is safe to operate, and supply of Home Energy for the Heating System/Source Crisis must be averted within 48 hours

Crisis must be averted within 18 hours Life Threatening Crisis Household is currently without heat. No operable Heating System or Heating Source. Crisis must be averted within 18 hours

11/13/2018 ECIP Benefit Amount Any remaining HEAP benefits and/or TANF Supplemental credits must be used in conjunction with or in lieu of ECIP funds ECIP maximum benefit equals $400 minus any remaining HEAP and TANF Supplemental Benefits 2015/2016 HEAP Training

October 25, 2017 Eligible Households May receive more than one ECIP benefit in a given Program Year if total benefits do not exceed $400 PY 2018 ECIP Training

Must be pre-authorized by CAA and included on purchase order ECIP - Allowable Uses Fuel type specified on purchase order Delivery fees and charges for restarts/safety checks Minor Heating System repairs Must be pre-authorized by CAA and included on purchase order

Other Allowable Uses Space heaters Temporary relocation Rent assistance for eviction due to non- payment of rent

Ineligible if household: Has received maximum ECIP for Program Year Has safe operating Heating System that adequately heats home during severe weather and has more than 3-day supply of Home Energy Client has means to purchase Home Energy

ECIP Role Play

CAA contacts vendor to: Verify last delivery information – date and number of units delivered Determine if Vendor will do an upfront delivery pending receipt of a HEAP Benefit Confirm Vendor can make delivery within required timeframe (i.e. 18 or 48 hours)

CAA contacts Vendor to: Confirm cash price per unit Determine amount of delivery charge (if any) Identify need and charges for restart or safety check

Vendor confirms HEAP units = HEAP credit ÷ cash price Oil/Kerosene: HEAP credit ÷ (cash price – $0.07) TANF Supp units = TANF credit ÷ cash price ECIP amount (fuel) = # units x cash price

Verbal purchase orders should be exception not standard practice CAA will email or fax purchase order to Vendor to confirm details of ECIP requirements and authorized dollar amount Verbal purchase orders should be exception not standard practice

Purchase Order Primary Applicant’s name & delivery address Home Energy type Dollar amount authorized by CAA (based on cash price quoted by Vendor plus delivery charges and costs for restart or safety check) Delivery time requirements (18 or 48 hours)

Vendor Responsibilities Refuse purchase order if cannot meet delivery time requirements Contact CAA immediately if full amount cannot be delivered ECIP deliveries must be reported on ACR, even if not regular client

ECIP Payments

Documentation Required for Payment Copy of Purchase Order Metered delivery ticket Invoice (if required)

Oil/Kerosene and Propane If amount on delivery ticket is greater than ECIP purchase order, notate ticket with dollar amounts paid by: ECIP HEAP or TANF Supplemental (if applicable) Customer or third-party (if applicable) Sign and date ticket

Vendor invoice required if: Delivery ticket does not account for all charges approved on purchase order (ex. delivery fees or restart/safety check charges)

ECIP Payments CAA reviews documentation and authorizes payment MaineHousing issues payment within 10 working days If payment is not received within appropriate timeframe, contact MaineHousing

Let’s look at a split-billed delivery Handouts Tab – Page 19

Vendor Agreement Reminders

Notify MaineHousing of Changes Contact information Banking information Mailing address Mergers/Acquisitions Tax ID information

Section 17 – Sale of Business Notify MaineHousing 30 days before closing or sale Return HEAP funds to MaineHousing Close-out audit to reconcile HEAP funds

Section 17 – Sale of Business Remaining HEAP funds must be returned to MaineHousing. Do not transfer HEAP funds to another company or HEAP Vendor, or issue directly to client.

Section 15 – Confidentiality Protection of Personally Identifiable Information (PII)

What is considered PII? Any information about a person that can be used to distinguish or trace a person’s identity HEAP client’s name and address

Put measures in place to prevent loss, theft, or inadvertent disclosure of PII

Paper Documents Remove from printers and fax machines Do not leave on work area unattended Place in locked files at end of day

Encrypt emails containing client names and addresses If you cannot encrypt: Use fax instead of email Ask CAA or MaineHousing to send you encrypted email (your reply will be encrypted)

If you suspect or become aware of a breach, notify MaineHousing immediately

Program Abuse

Examples of Program Abuse Not including household members on application Failure to disclose income (most often self- employment or rental income) Household does not live in home during the winter months

Report suspected program abuse to: 1-800-452-4668 MaineHousing 353 Water St, Augusta, ME 04330 liheapcompliance@mainehousing.org

New HEAP Database

Wrap-up and Evaluations

Energy & Housing Services liheap@mainehousing.org