GAO-12-848R Home Energy Assistance

United States Government Accountability Office

Washington, DC 20548

August 24, 2012

The Honorable Jeff Bingaman

Chairman

Committee on Energy and Natural Resources

United States Senate

The Honorable Jon Tester

United States Senate

Subject: Home Energy Assistance for Low-Income Occupants of Manufactured 

Homes

According to the Energy Information Administration (EIA),1 the nation’s approximately 130 

million housing units account for about 23 percent of total energy consumption in the United 

States. Approximately 2 million of these housing units are manufactured homes (i.e., mobile 

homes) that were built prior to 1976, when new standards for energy efficient construction

became effective.2

 1

EIA in the U.S. Department of Energy collects, analyzes, and disseminates a wide range of information and data 

products covering energy production, stocks, demand, imports, exports, and prices. EIA then prepares analyses 

and special reports on topics of current interest. 

 These older manufactured homes are generally considered to have 

some of the poorest energy efficiency of all housing units. Many of the occupants of these 

homes qualify for federal assistance to help pay their energy bills through the U.S. 

Department of Health and Human Services’ (HHS) Low Income Home Energy Assistance 

Program (LIHEAP). LIHEAP helps cover home energy expenditures— key components of 

which are home heating and, in some cases, cooling expenditures. In 2009, LIHEAP 

covered about 8.3 million low-income households through payments to homeowners, 

occupants, landlords, or others. LIHEAP is a federally funded block grant program in which 

funds are provided to grantees, including states, territories, and tribes and tribal 

2

In 1976, as a result of the National Manufactured Home Construction and Safety Standards Act of 1974 (Pub. L. 

No. 93-383, as amended, 42 U.S.C. § 5401 et seq.), the U.S. Department of Housing and Urban Development 

(HUD) began to issue and enforce standards for the construction, design, performance and installation of 

manufactured homes to ensure that they were more energy efficient, among other things. Consistent with these 

standards, for the purposes of this report, we consider manufactured homes to include any home that is 

constructed, and then transported to a site where it is occupied as a permanent residence. These definitions are 

consistent with the federal building code administered by HUD and the definitions used by EIA to collect 

information on housing. These codes and definitions do not consider prefabricated structures that are assembled 

on site to be manufactured homes.
Page 2 GAO-12-848R Home Energy Assistance

organizations, based on a number of factors, such as climate and income. Grantees then 

provide LIHEAP funds to eligible beneficiaries. To be eligible, household income must be 

below varying thresholds set by the federal government. In fiscal year 2012, Congress 

appropriated about $3.5 billion for LIHEAP nationwide. 

Questions have been raised about whether improving the energy efficiency of older 

manufactured homes or replacing them with newer, more energy-efficient models would

save the federal government money by reducing LIHEAP costs. A portion of LIHEAP funds 

can be used to improve the energy efficiency of these homes but, in many cases, because 

of the ways these homes were built and their sometimes poor condition, improving their 

energy efficiency cannot be accomplished cost effectively. LIHEAP funds are statutorily 

prohibited from being used for new construction, which includes replacing existing homes. 

You asked us to review available data on energy use by and LIHEAP assistance for 

occupants of manufactured homes––particularly those built before 1976. Our objectives for 

this report were to determine (1) the amount occupants of older manufactured homes paid 

for energy and how it compared with the amount paid by occupants of detached homes, (2) 

how the amount of LIHEAP assistance occupants of older manufactured homes received 

and the amount of their energy expenditures this assistance covered compared with such 

assistance received and expenditures covered for occupants of detached homes, and (3) 

the proportion of total LIHEAP funding used to assist occupants of older manufactured 

homes.3

To address these objectives, we analyzed the EIA Residential Energy Consumption Survey 

(RECS) data for 2005—the most recent year for which data were available.4

 In addition, 

the 2005 RECS data were divided into manufactured homes, site-built detached homes, 

site-built attached homes, and apartments of any size.5

 3

We also have ongoing work examining how some states or localities have leveraged private, state, local, and 

other funds to replace older manufactured homes with newer, more energy-efficient models and the extent to 

which doing so may result in cost savings. We expect to issue a separate report on these findings in early 2013. 

 HHS signed an interagency 

agreement with EIA for use of the RECS data to match with state and local LIHEAP

4

EIA administers RECS every 4 years to a nationally representative sample of housing units to collect energy 

characteristics on the housing unit, usage patterns, and household demographics. RECS seeks information 

primarily about primary residential housing units—excluding unoccupied housing and secondary housing units 

such as vacation homes—including questions about housing types and year of construction, as well as questions 

related to household income. Data on home energy expenditures includes heating and cooling bills from the 

following energy sources: electricity, natural gas, fuel oil, kerosene, propane, wood, coal, or solar. 

5

EIA defines detached homes as single-family houses as long as they are not divided into more than one 

housing unit and have an independent outside entrance. A single-family house is contained within walls 

extending from the basement (or the ground floor, if there is no basement) to the roof. Townhouses, rowhouses, 

and duplexes are considered single-family attached housing units as long as there is no household living above 

another one within the walls extending from the basement to the roof to separate the units.
Page 3 GAO-12-848R Home Energy Assistance

beneficiaries.6 We used the resulting matched data to determine the average income, size, 

energy expenditures, as well as information on LIHEAP payments by housing type and year 

of construction. Because the sample size in RECS for households that received LIHEAP 

assistance was relatively small, estimates using these data should be considered a midpoint 

within a range rather than an exact estimate. To assess the reliability of the 2005 RECS 

data and the matched HHS data, we compared the data with other EIA documents, 

electronically tested the data for consistency, and discussed the data with knowledgeable 

EIA officials; we determined that the data were sufficiently reliable for the purposes of this 

report.7

 We surveyed LIHEAP grantees––including all 50 states and the District of 

Columbia, 152 tribes and tribal organizations, and 5 U.S. territories––to determine the extent 

to which they collect data on LIHEAP recipients’ housing types and years of construction.8

 

We received responses from 141 grantees––about a 68 percent response rate. In addition, 

we met with officials from HHS and EIA, as well as state officials from Maine and Montana––

because these states have conducted pilot programs to replace older manufactured homes 

with newer, more energy-efficient models. We also interviewed officials from organizations 

and agencies that conduct research or represent the interests of LIHEAP officials and 

grantees, including the National Energy Assistance Directors’ Association, National 

Consumer Law Center, NeighborWorks America, Apprise Inc., and the American Gas 

Association. A more detailed description of our objectives, scope, and methodology is 

provided in enclosure I. 

We conducted this performance audit from November 2011 to August 2012 in accordance 

with generally accepted government auditing standards. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on 

our audit objectives.

In summary, in 2005, the most recent year for which complete data were available, 

occupants of older manufactured homes paid over twice as much on average per square 

foot for energy—$1.75 per square foot as compared with $0.87—as was paid by occupants 

 6 According to HHS officials, the purpose of the administrative records matching initiative was to improve the 

quality of data for LIHEAP recipients, including the validity of the recipient’s data, the quality of the information on 

the types and amount of LIHEAP assistance received, and information on both LIHEAP recipients and LIHEAP 

eligible nonrecipients.

7 For purposes of this report, we refer to these data as 2005 RECS data.

8

The U.S. territories include American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. 

Virgin Islands.
Page 4 GAO-12-848R Home Energy Assistance

of detached homes.9 Annual energy expenditures for older manufactured homes––about 

906 square feet on average––were about $1,369, compared with detached homes––about 

2,919 square feet on average—were about $2,060. Energy expenditures—both per square 

foot and annually—varied significantly by region reflecting regional differences in the types 

and costs of fuels commonly used to heat and cool homes, income levels, and climate, 

among other things. In 2005, LIHEAP provided more assistance on a per square foot 

basis—about $0.33 per square foot—to occupants of older manufactured homes than to 

those of detached homes—about $0.20 per square foot. However, this assistance covers 

slightly less of the annual energy expenditures of occupants of older manufactured homes 

than occupants of detached homes—15 and 17 percent, respectively. Based on our 

analysis of EIA’s RECS data, we estimate that about 3 percent of LIHEAP funds—about $57 

million—spent in 2005 were used to assist occupants of older manufactured homes.

Background

A manufactured home is constructed almost entirely in a factory and transported to the site 

where it will be occupied, in contrast to a site-built home, which is constructed at the site 

where it will be occupied. Many manufactured homes are rectangular, wood-framed, 

aluminum-sided, single-story structures––commonly known as "mobile homes" or “house 

trailers”––built on a metal frame that can be placed on wheels or on the back of a 

commercial-grade truck and transported to sites where they are generally permanently 

installed. Camping or travel trailers—typically smaller structures that can be pulled by car or 

small truck––are another type of manufactured home but are generally designed to be 

temporary dwellings rather than permanent residences.

To implement the National Manufactured Housing Construction and Safety Standards Act of 

1974, the Department of Housing and Urban Development (HUD) began to issue and 

enforce standards for the construction, design, performance, and installation of 

manufactured homes to ensure their quality, durability, affordability, and safety. HUD may 

enforce these standards directly, or they may be enforced at the state level. These 

standards preempt state and local laws that are not identical to the federal standards and 

apply to all manufactured homes produced after June 15, 1976. 

Prior to 1976, there were few provisions for ensuring the safety or quality of manufactured 

homes. Many of these older homes were built with little or no insulation, thin walls and 

 9

Due to significant size differences between older manufactured homes and detached homes, we calculated

energy expenditures on a per square foot basis for purposes of comparison.
Page 5 GAO-12-848R Home Energy Assistance

roofs, uninsulated heating and cooling systems, and inefficient louvered windows (known as 

jalousie windows). Further, over time many of these older manufactured homes have 

deteriorated to the point that their windows and doors no longer seal tightly to protect the 

interior from the weather. According to the Maine Housing Authority, which conducted a 

study in 2007 of pre-1976 manufactured homes, many of these older manufactured homes 

have depreciated to the point where they have no market value. In addition, housing and 

weatherization experts have stated that some pre-1976 manufactured homes may be 

unsuitable for weatherization (i.e., making long-term energy efficiency improvements). For 

example, these homes typically have roofs made of thin metal sheets seamed together and 

walls built with 2-inch by 2-inch studs; therefore, neither the ceilings nor the walls can 

accommodate insulation.10 In addition, most of these older manufactured homes are beyond 

the scope of federal and state weatherization programs;11 that is, officials responsible for 

implementing these programs have generally determined that such homes are too 

deteriorated to warrant weatherization or are unsafe for weatherization crews to work on. 

Approximately 80 percent of older manufactured homes are in the South and West U.S. 

Census Regions as are approximately 84 percent of newer manufactured homes.12 Figure 

1 presents an example of a manufactured home that was built prior to 1976,

 10Standards for homes built after 1976 require 2-inch by 6-inch wall studs. 11DOE’s Weatherization Assistance Program was created in 1976 under Title IV of the Energy Conservation and 

Production Act. By making long-term energy efficiency improvements, such as installing insulation, sealing 

leaks, and modernizing heating and air conditioning equipment, the weatherization program aims to, among 

other things, increase the energy efficiency of homes owned or occupied by low-income persons, reduce their 

total residential energy expenditures, improve their health and safety, and reduce the burden of energy prices. 

DOE makes weatherization program funds available through formula-based grants to agencies in the 50 states, 

the District of Columbia, U.S. territories, and American Indian tribes and tribal organizations. 12 The U.S. Census Bureau divides the United States into four regions. Each region includes several states: 

Northeast Region (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, Connecticut, New York, 

New Jersey, and Pennsylvania); Midwest Region (Ohio, Indiana, Illinois, Michigan, Wisconsin, Minnesota, Iowa, 

Missouri, North Dakota, South Dakota, Nebraska, and Kansas); South Region (Delaware, Maryland, District of 

Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia, Florida, Kentucky, Tennessee, 

Alabama, and Mississippi, Arkansas, Louisiana, Oklahoma, and Texas); and West Region (Montana, Idaho, 

Wyoming, Colorado, New Mexico, Arizona, Utah, Nevada, Washington, Oregon, California, Alaska, and Hawaii).
Page 6 GAO-12-848R Home Energy Assistance

Figure 1: Pre-1976 Manufactured Home 

Title XXVI of the Omnibus Budget Reconciliation Act of 1981 established LIHEAP to help 

low-income households––particularly those with the lowest incomes that pay a high 

proportion of household income on home energy expenditures––pay their home heating and 

cooling costs.13 LIHEAP is a federal block grant program that provides funding grants to 

states and other entities that, in turn, provide the funds to eligible households. States, 

territories, and tribes and tribal organizations that wish to assist low-income households in 

meeting home energy expenditures may apply for a LIHEAP block grant. These grantees 

then provide payments on behalf of the eligible households directly to homeowners, 

occupants, landlords or others. Grantees provide LIHEAP assistance to eligible 

beneficiaries up to the maximum eligible payment for that beneficiary as determined by the 

grantee. Grant funds are distributed in this manner until the grantees’ annual funding has 

been entirely expended or the fiscal year has ended. LIHEAP funding, adjusted for inflation, 

was highest from 1981-1986 and from 2009-2011, witnessing a decline in real terms in the 

years in between (see fig. 2). For 2012, LIHEAP allocated to state grantees funding that 

ranged from about $6.1 million, for Hawaii, to about $375.5 million, for New York. For 2012, 

LIHEAP allocated to U.S. territory grantees funding that ranged from about $58.7 thousand, 

for the Northern Mariana Islands, to about $4.2 million, for Puerto Rico and for all tribes and 

tribal organizations funding of about $38.4 million. Enclosure II includes detailed LIHEAP 

funding by state, territory, and tribes or tribal organizations for 2012.

 13Pub. L. No. 97-35, 95 Stat. 357 (1981). 
Page 7 GAO-12-848R Home Energy Assistance

Figure 2: LIHEAP Funding History

LIHEAP statutes establish overall LIHEAP guidelines, within which each grantee operates 

its own program. For example, HHS guidelines specify that a LIHEAP-eligible household’s 

income generally must not exceed the greater of 150 percent of the poverty level or 60 

percent of the state’s median income. These guidelines also stipulate that LIHEAP grantees 

may not set their maximum income threshold for applicants below 110 percent of the 

poverty level, but they may give priority to those households with the highest home energy 

expenditures or needs in relation to income. LIHEAP grantees may set additional criteria for 

allocating LIHEAP funding to recipients. For example, they may give priority to households 

with vulnerable occupants, which HHS defines as those who are at least 60 years old, 

disabled, or 5 years old or younger. 
Page 8 GAO-12-848R Home Energy Assistance

LIHEAP does not require grantees to match federal funds, but some grantees choose to 

supplement funds. Grantees also have the flexibility to use up to 15 percent of their LIHEAP 

funds––or up to 25 percent under certain circumstances––for state weatherization programs 

that provide funds to improve home energy efficiency, typically by upgrading insulation and 

heating and cooling equipment.14 However, both LIHEAP and the weatherization funds are 

precluded from being used for new construction, which would also preclude replacing 

existing homes with newer, more efficient models. 

Occupants of Older Manufactured Homes Paid More Than Twice as Much per 

Square Foot for Energy than Occupants of Detached Homes in 2005

In 2005, the most recent year for which complete data were available, occupants of older 

manufactured homes paid, on average, more than twice as much for energy per square foot 

than did occupants of detached homes.15 Specifically, according to our analysis of EIA’s 

2005 RECS data, annual energy expenditures for older manufactured homes averaged 

about $1.75 per square foot compared to $0.87 for detached homes. However, because 

manufactured homes tend to be smaller than detached homes, these differences do not 

necessarily translate to higher annual energy expenditures. Based on the 2005 RECS data, 

we estimated that annual energy expenditures for an older manufactured home were $1,369 

per year, with energy expenditures ranging from $353 to $4,659. The average size of these 

homes was about 906 square feet. In contrast, average annual energy expenditures for 

detached homes were about $2,060 per year, with energy expenditures ranging from $57 to 

$10,346.16 The average size of these homes was about 2,919 square feet. Figure 3 

compares the average energy expenditures per square foot and annually for older 

manufactured and detached homes. Additional information on energy expenditures and 

home size by housing type––including apartments and attached homes––as well as by year 

of construction can be found in tables 4 and 5 in enclosure III.

 14HHS evaluates states’ requests to use up to 25 percent of LIHEAP funds for weatherization programs. 15Due to significant size differences between older manufactured homes and detached homes, we calculated 

energy expenditures on a per square foot basis for purposes of comparison. 16These averages were separately derived from the 2005 RECS database. There is a direct relationship between 

energy expenditures and household square footage. As such, the ratio of these averages (average energy 

expenditures divided by average square footage) will not equal the average of their ratio (average of the ratio of 

energy expenditures to square footage). 
Page 9 GAO-12-848R Home Energy Assistance

Figure 3: Average Energy Expenditures per Square Foot and Annually for Older 

Manufactured Homes and Detached Homes, 2005 

We also analyzed energy expenditures for occupants of all housing types by the nine U.S. 

Census divisions and found that the average energy expenditures per square foot ranged 

from about $0.92 in the East North Central Division (Ohio, Indiana, Illinois, Michigan, and 

Wisconsin) to about $1.45 in the New England Division (Maine, New Hampshire, Vermont, 

Massachusetts, Rhode Island, and Connecticut).17 Average annual energy expenditures 

ranged from $1,421 in the Pacific Division (Washington, Oregon, California, Alaska, and 

Hawaii) to $2,428 in the New England Division (see table 1). These differences in energy 

expenditures reflect a number of factors including regional differences in the type and costs 

of fuels commonly used to heat and cool homes, income levels, and climate. 

 17EIA calculates energy expenditures per square foot using a different method than we used in our analysis. 

However, EIA acknowledged that both methods are valid, and our method is appropriate for our analysis.
Page 10 GAO-12-848R Home Energy Assistance

Table 1: Average Energy Expenditures and Home Size for Occupants of All Housing Types by U. S. 

Census Division, 2005

U.S. Census division Average energy 

expenditures per square 

foot (in dollars)

Average annual energy 

expenditures (in dollars)

Average home size 

(in square feet)

New England $1.45 $2,428 2,529

Middle Atlantic 1.44 2,279 2,376

East North Central 0.92 1,808 2,628

West North Central 0.93 1,735 2,424

South Atlantic 0.99 1,704 2,370

East South Central 0.98 1,674 2,254

West South Central 1.17 1,903 2,184

Mountain 1.01 1,644 2,149

Pacific $0.95 $1,421 1,878

Source: GAO analysis of EIA’s RECS data.

Note: The U.S. Census Bureau divides the United States into nine divisions. Each division includes several 

states: New England Division (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, and 

Connecticut); Middle Atlantic Division (New York, New Jersey, and Pennsylvania); East North Central Division 

(Ohio, Indiana, Illinois, Michigan, and Wisconsin); West North Central Division (Minnesota, Iowa, Missouri, North 

Dakota, South Dakota, Nebraska, and Kansas); South Atlantic Division (Delaware, Maryland, District of 

Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia, and Florida); East South Central 

Division (Kentucky, Tennessee, Alabama, and Mississippi); West South Central Division (Arkansas, Louisiana, 

Oklahoma, and Texas); Mountain Division (Montana, Idaho, Wyoming, Colorado, New Mexico, Arizona, Utah, 

and Nevada); Pacific Division (Washington, Oregon, California, Alaska, and Hawaii). U. S. Census divisions 

differ from the four U. S. Census regions.

In addition, we analyzed RECS data to determine how many occupants have incomes below 

150 percent of states’ varying poverty levels—one of the thresholds for qualifying for 

LIHEAP assistance––by housing type. We found that, in 2005, about 55.0 percent of 

occupants living in older manufactured homes had incomes that met this threshold, and 

about 18.5 percent of occupants living in detached homes met it (see fig. 4). Additional 

information on occupants whose incomes were below this threshold by housing type and 

year of construction can be found in table 7 in enclosure III.
Page 11 GAO-12-848R Home Energy Assistance

Figure 4: Percentage of Occupants with Incomes below 150 Percent of the Poverty 

Level by Housing Type, 2005 

LIHEAP Provided More Assistance per Square Foot to Occupants of Older 

Manufactured Homes Than to Occupants of Detached Homes in 2005

In 2005, LIHEAP provided more assistance per square foot to occupants of older 

manufactured homes than to occupants of detached homes, but this assistance covered 

slightly less of the annual energy expenditures for occupants of older manufactured homes 

as compared with occupants of detached homes. However, LIHEAP assistance provided 

less annual support for occupants living in older manufactured homes than for those living in 

detached homes, in part, because these manufactured homes are smaller. Specifically, 

occupants of older manufactured homes received about $0.33 per square foot in LIHEAP 

assistance, or about $214 per year, covering about 15 percent of their annual energy 

expenditures. In contrast, occupants of detached homes received about $0.20 per square 

foot in LIHEAP assistance, or about $345 per year, which covered about 17 percent of their 

annual energy expenditures. 18

 18Average LIHEAP payments per square foot were derived by dividing each individual household’s LIHEAP 

payment by its square footage then averaging the result. This will yield a different result from dividing the 

average LIHEAP payment for all households by the average total square footage because LIHEAP payments 

and square footage are related to each other.

The range of LIHEAP assistance for older manufactured 

homes was $0.10 to $1.55 per square foot, or $60 to $776 annually. The range of LIHEAP 

assistance for detached homes was $0.01 to $1.43 per square foot, or $14 to $975 annually. 
Page 12 GAO-12-848R Home Energy Assistance

Figure 5 shows average LIHEAP assistance per square foot by type of home. Additional 

information about energy expenditures and LIHEAP assistance by housing type and year of 

construction, including information on housing size, can be found in table 8 in enclosure III. 

Figure 5: Average LIHEAP Assistance per Square Foot, 2005 

LIHEAP assistance also varied across U.S. Census divisions in 2005. For instance, LIHEAP 

assistance per square foot ranged from about $0.16 in the Middle Atlantic Division (New 

York, New Jersey, and Pennsylvania) to $0.42 in the New England Division, or $262 and 

$476 total LIHEAP assistance per year, respectively (see table 2). Such variations can 

result from a number of different factors including climate, the ways various states 

implement their block grant programs, and differences in the types and costs of fuel used to 

heat and cool homes. 
Page 13 GAO-12-848R Home Energy Assistance

Table 2: Average LIHEAP Assistance for Occupants of All Housing Types by U.S. Census Division, 2005

U.S. Census division Average LIHEAP 

assistance as a 

percentage of total 

energy expenditures

Average LIHEAP 

assistance per square 

foot (in dollars)

Average annual LIHEAP 

assistance (in dollars)

New England 25.26 $0.42 $476

Middle Atlantic 15.19 0.16 262

East North Central 18.62 0.22 296

West North Central 21.48 0.24 285

South Atlantic 0.21 a 250

East South Central 16.84 0.17 192

West South Central a 526 a

Mountain 0.21 a 285

Pacific 29.72 $0.35 $231

Source: GAO analysis of EIA’s RECS data.

Note: The U.S. Census Bureau divides the United States into nine divisions. Each division includes several 

states: New England Division (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, and 

Connecticut); Middle Atlantic Division (New York, New Jersey, and Pennsylvania); East North Central Division 

(Ohio, Indiana, Illinois, Michigan, and Wisconsin); West North Central Division (Minnesota, Iowa, Missouri, North 

Dakota, South Dakota, Nebraska, and Kansas); South Atlantic Division (Delaware, Maryland, District of 

Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia, and Florida); East South Central 

Division (Kentucky, Tennessee, Alabama, and Mississippi); West South Central Division (Arkansas, Louisiana, 

Oklahoma, and Texas); Mountain Division (Montana, Idaho, Wyoming, Colorado, New Mexico, Arizona, Utah, 

and Nevada); Pacific Division (Washington, Oregon, California, Alaska, and Hawaii). U. S. Census divisions 

differ from the four U. S. Census regions.

a

Calculated value is not reliable because either (1) the relative standard error was less than 2, or (2) the number 

of observations used to calculate the mean estimate was less than 10.

About 3 Percent of LIHEAP Funds in 2005 Were Used to Assist Occupants of Older 

Manufactured Homes

We estimate that about 3 percent of LIHEAP funds—about $55 million—in 2005 were used 

to assist occupants of older manufactured homes, even though older manufactured homes 

represented about 1.7 percent of the primary, occupied housing units in the United States.19

The data and methodology used by EIA in RECS limit our ability to definitively determine 

certain aspects of the LIHEAP assistance occupants of older manufactured homes 

received.20

 19We developed this estimate using 2005 RECS data because HHS and LIHEAP grantees do not routinely 

collect data that would allow us to determine the percentage of LIHEAP funding annually used to help occupants 

of older manufactured homes. We derived the $55 million by multiplying the portion of LIHEAP funds spent in 

2005 to assist occupants of older manufactured homes–– about 3 percent––by the $1.88 billion in total 

distributed LIHEAP funds in fiscal year 2005.

However, it appears that occupants of older manufactured homes were more 

likely to receive LIHEAP assistance than occupants of detached homes, since they received 

20The sample size for households that received LIHEAP assistance was too small to provide reliable estimates to 

project to some subcategories such as housing types and year of construction. For more details, see enclosure I.
Page 14 GAO-12-848R Home Energy Assistance

a disproportionate share of the assistance relative to the share of the universe of housing 

stock, even though they generally received smaller payments.

Because LIHEAP is a federal block grant program focused on assisting low-income 

households, HHS collects data from LIHEAP grantees on the number of households 

receiving assistance, their income, and the number of their households with vulnerable 

occupants;

21 however, it does not require grantees to collect information on LIHEAP 

recipients’ housing type or year of construction. As a result, we surveyed grantees (i.e., 50 

states and the District of Columbia, 152 tribes and tribal organizations, and 5 U.S. territories) 

to identify how many collected information on housing type and year of construction from 

LIHEAP recipients. Of the 141 grantees that responded to our survey of state and tribal 

grantees, we found that 7 grantees collect this information. In the absence of detailed 

information from HHS or LIHEAP grantees, we developed an estimate of the percentage of 

LIHEAP funding provided to occupants of older manufactured homes based on an analysis 

that HHS undertook that matched 2005 RECS data with LIHEAP recipient rolls. For the 

2009 RECS survey—expected to be released later this year—EIA has worked with HHS to 

incorporate questions related to improving the data available regarding low-income housing 

units. 

Agency Comments

We provided a draft of this report for review and comment to HHS. HHS provided technical 

and clarifying comments, which we incorporated as appropriate.

- - - - -

We are sending copies of this report to the appropriate congressional committees, the 

Secretary of Health and Human Services, the Secretary of Energy, and other interested 

parties. In addition, this report is available at no charge on the GAO website at 

http://www.gao.gov.

 21HHS defines vulnerable occupants as an occupant who is 60 year old or older, disabled, or 5 years old or 

younger. LIHEAP requires states to report these data on these occupants annually.
Page 15 GAO-12-848R Home Energy Assistance

If you or your staff members have any questions about this report, please contact me at 

(202) 512-3841 or ruscof@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. GAO staff 

who made key contributions to this report are listed in enclosure IV. 

Frank Rusco

Director, Natural Resources and Environment

Enclosures
Page 16 GAO-12-848R Home Energy Assistance

Enclosure I: Objectives, Scope, and Methodology

This report examines energy expenditures and Low Income Home Energy 

Assistance Program (LIHEAP) assistance for occupants of manufactured homes––

particularly those built before 1976—and detached homes. Our objectives for this 

report were to determine (1) the amount occupants of older manufactured homes 

paid for energy and how it compared with the amount paid by occupants of detached 

homes, (2) how the amount of LIHEAP assistance occupants of older manufactured 

homes received and the amount of their energy expenditures this assistance 

covered compared with such assistance received and expenditures covered for 

occupants of detached homes, and (3) the proportion of total LIHEAP funding used 

to assist occupants of older manufactured homes.22

In conducting our work, we reviewed relevant laws including Title XXVI of the 

Omnibus Budget Reconciliation Act of 1981 and the National Manufactured Home 

Construction and Safety Standards Act of 1974. We also reviewed Health and 

Human Services’ (HHS) reports to Congress and LIHEAP Home Energy 

Notebooks.23 We met with officials from HHS, the Department of Energy’s Energy 

Information Administration (EIA),24 and the LIHEAP Clearinghouse––an aggregator 

of LIHEAP data. We also met with state officials from the states of Maine and 

Montana because these states have conducted pilot programs to replace pre-1976 

manufactured homes with newer, more energy-efficient models. In addition, we 

interviewed officials from organizations and agencies that conduct research or 

represent the interests of LIHEAP officials and grantees including the National 

Energy Assistance Directors’ Association, National Consumer Law Center, 

NeighborWorks America, Apprise Inc., and the American Gas Association.

 22We also are doing ongoing work examining how some states or localities have leveraged private, state, local, 

and other funds to replace older manufactured homes with newer, more energy-efficient models and the extent 

to which doing so may result in cost savings. We expect to issue a separate report on these findings in early 

2013. 23HHS publishes the LIHEAP Home Energy Notebook, as a supplement to their report to Congress. This 

publication provides LIHEAP grantees and other interested parties the most recent data on home energy usage, 

consumption, and expenditures for all, low income, non-low income, and LIHEAP recipient households. 24EIA collects, analyzes, and disseminates a wide range of information and data products covering energy 

production, stocks, demand, imports, exports, and price; and prepares analyses and special reports on topics of 

current interest. 
Page 17 GAO-12-848R Home Energy Assistance

To determine how much occupants of older manufactured homes pay for energy and the 

proportion of LIHEAP funding used to assist occupants of older manufactured homes, we 

analyzed data from EIA’s Residential Energy Consumption Survey (RECS) from 2005, 

which was the most recent year for which complete data were available.25 RECS is 

conducted periodically from a random sample of primary, occupied housing units in the 

United States. The “Household Survey” phase of the 2005 RECS was conducted in late 

2005. EIA supplemented its 2005 RECS data with data from a separate RECS “Energy 

Supplier Survey,” conducted in 2006, which collected energy expenditure data from 

responding households. The RECS data on the year homes were built are available in 10-

year increments; therefore, we relied on RECS data from 1979 and before as a proxy for 

pre-1976 housing in our analysis of older manufactured homes. Because manufactured 

homes built from 1977 through 1979 were subject to higher energy efficiency standards than 

were pre-1976 manufactured homes, the inclusion of data on homes built in these 3 years 

likely creates a downward bias in our estimates of energy expenditures of pre-1976 

manufactured homes. However, because the stock of pre-1976 manufactured homes is 

large relative to the inclusion of homes built in these 3 years, this bias is likely small. In 

addition, the 2005 RECS data were divided into manufactured homes, site-built detached 

single-family homes (detached homes), site-built attached single-family homes (attached 

homes), and apartments of any size.26 

For the 2005 RECS, EIA interviewed a sample of occupants of homes in the United States 

and asked respondents questions about housing unit types, year of construction, and 

household income, among other things. These occupants were selected using a nationwide 

random sample. HHS signed an interagency agreement with EIA for use of the RECS data 

to match with state and local LIHEAP beneficiaries. According to HHS officials, the purpose 

of the administrative records matching initiative was to improve the quality of data for 

LIHEAP recipients, including

• validity of the recipient’s data,

• quality of the information on the types and amount of LIHEAP assistance 

received, and

• information on both LIHEAP recipients and LIHEAP eligible nonrecipients.

 25EIA administers RECS to a nationally representative sample of housing units to collect energy characteristics 

on the housing unit, usage patterns, and household demographics. RECS includes questions about housing unit 

types and year of construction, as well as questions related to household income. 26Detached homes are considered single-family houses as long as they are not divided into more than one 

housing unit and have an independent outside entrance. A single-family house is contained within walls 

extending from the basement (or the ground floor, if there is no basement) to the roof. Townhouses, rowhouses, 

and duplexes are considered single-family attached housing units, as long as there is no household living above 

another one within the walls extending from the basement to the roof to separate the units.
Page 18 GAO-12-848R Home Energy Assistance

We used the resulting matched data to determine the average income, size, and energy 

expenditures, as well as information on LIHEAP payments by housing type and year of 

construction. The 2005 RECS uses a complex sampling design which, after applying 

weights to the observations, allowed us to project to all households. However, the sample 

size for households that received LIHEAP assistance was 434––a relatively small sample 

size, particularly when these data are divided into categories such as housing types and 

year of construction. Although the sample sizes were too small to provide reliable results 

for us to project to a few subcategories, the data for LIHEAP recipients of manufactured 

homes built in 1979 and before were reliable; but due to their small sizes, we have primarily 

drawn broad aggregative conclusions about this subcategory. Because of the relatively 

small sample size, in cases where we examine characteristics of LIHEAP recipients, our 

estimates may have a higher standard error and should therefore be considered a midpoint 

within a range rather than an exact estimate of the actual value. In general, we present only 

those estimates for all housing classifications that meet EIA’s criteria for reporting an 

estimate using the 2005 RECS data. Specifically, these criteria are: (1) that the mean of 

each variable divided by its standard error is at least 2 and (2) the number of observations 

used to calculate the mean estimate should be at least 10. We used these criteria to 

determine the reliability of our calculations. To assess the reliability of the 2005 RECS data 

and the matched HHS data, we compared the data with other EIA documents, electronically 

tested the data for consistency, and discussed the data with knowledgeable EIA officials. 

Overall, we determined that these data were sufficiently reliable for the purposes of this 

report.

To determine the proportion of LIHEAP funding used to assist occupants of older 

manufactured homes, we used the matched HHS data. Since the results were very broad 

aggregative estimates, we also surveyed LIHEAP grantees––including all 50 states and the 

District of Columbia, 152 tribes and tribal organizations, and 5 U.S. territories––to determine 

the extent to which they collect data on LIHEAP recipients’ housing types and years of 

construction.27 To ensure the reliability and validity of the questions, we pretested the survey 

with two state officials. We received responses from 141 grantees including 49 states, the 

District of Columbia, 86 tribes and tribal organizations, and all 5 U.S. territories,28

 27The U.S. territories include American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. 

Virgin Islands.

—about a 

28Louisiana declined to respond to our survey, citing resource constraints.
Page 19 GAO-12-848R Home Energy Assistance

68 percent response rate. However, HHS and LIHEAP grantees did not routinely collect 

data that would allow us to determine the percentage of LIHEAP funding annually used to 

help occupants of older manufactured homes; therefore, we derived our estimate by 

multiplying the portion of LIHEAP funds spent in 2005 to assist occupants of older 

manufactured homes–– about 3 percent––by the $1.88 billion in total distributed LIHEAP 

funds in fiscal year 2005.

We conducted this performance audit from November 2011 to August 2012 in accordance 

with generally accepted government auditing standards. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on 

our audit objectives.
Page 20 GAO-12-848R Home Energy Assistance

Enclosure II: LIHEAP Funding Allocations by State, Territory, and Tribe and 

Tribal Organization, 2012

States

Total LIHEAP 

allocations

(in dollars)

Alabama

a

$47,081,144

Alaska 10,641,099

Arizona 21,904,148

Arkansas 28,537,364

California 153,259,035

Colorado 47,308,286

Connecticut 79,531,964

Delaware 11,956,809

District of Columbia 10,687,141

Florida 78,019,715

Georgia 61,702,366

Hawaii 6,107,011

Idaho 19,577,889

Illinois 185,683,819

Indiana 79,998,845

Iowa 54,812,821

Kansas 32,118,334

Kentucky 46,423,070

Louisiana 43,421,576

Maine 38,520,365

Maryland 69,790,309

Massachusetts 132,678,036

Michigan 172,428,540

Minnesota 116,838,721

Mississippi 31,530,677

Missouri 68,231,128

Montana 19,915,857

Nebraska 30,207,576

Nevada 11,202,561

New Hampshire 26,055,007

New Jersey 136,745,901

New Mexico 15,715,158

New York 375,509,667

North Carolina 81,534,565

North Dakota 20,554,636

Ohio 165,463,488

Oklahoma 32,787,515

Oregon 36,012,085

Pennsylvania 209,548,185

Rhode Island 23,175,439

South Carolina 36,269,889

South Dakota 17,507,368

Tennessee 55,405,327

Texas 129,832,056

Utah 24,100,402
Page 21 GAO-12-848R Home Energy Assistance

Vermont 19,529,156

Virginia 80,436,332

Washington 57,967,554

West Virginia 29,699,517

Wisconsin 105,171,626

Wyoming 9,501,674

Total LIHEAP funding allocations to states $3,398,638,753

Total LIHEAP funding allocations to tribes 

and tribal organizations $38,428,998

Territories

American Samoa $77,107

Guam 169,052

Northern Marianas 58,717

Puerto Rico 4,196,331

Virgin Islands 159,857

Total LIHEAP funding allocations to U.S. 

territories $4,661,064

Total LIHEAP funding $3,471,672,115

Source: LIHEAP Clearinghouse.

a This total does not include rescission that was retained by HHS for training and technical assistance, as well as 

various grants distributed during the year.
Page 22 GAO-12-848R Home Energy Assistance

Enclosure III: Energy Expenditures and LIHEAP Assistance for Manufactured, 

Detached, Attached and Apartment Homes

This enclosure provides information on energy expenditures and LIHEAP assistance 

to supplement the data represented in figures and tables in the report.29

Table 3: Average Energy Expenditures and Home Size for Occupants of All Types of Housing, 2005

 Table 3 

provides energy expenditures and home size for occupants of all types of housing, 

including homes whose occupants who did not receive LIHEAP assistance. Tables 

4 and 5 provide energy expenditures by housing types, year of construction, and 

size. Table 6 provides LIHEAP assistance by housing types and year of 

construction. Table 7 provides the percentage of occupants with incomes below 150 

percent of the poverty level by housing types and year of construction. Table 8 

provides LIHEAP recipients’ energy expenditures and amounts of LIHEAP 

assistance for occupants of manufactured, detached, attached, and apartment 

homes, as well as home size. Table 9 provides energy expenditures and LIHEAP 

assistance by rural and nonrural areas. Table 10 provides average LIHEAP 

assistance for recipients for various income ranges.

Occupants Average energy 

expenditures per 

square foot 

Average annual energy 

expenditures

Average home size (in 

square feet)

That received LIHEAP 

assistance

$1.43 $1,756 1,671

That did not receive 

LIHEAP assistance

$1.06 $1,812 2,324

Source: GAO analysis of EIA’s RECS data.

 29According to EIA, energy expenditures consist of money spent for the energy used in, or delivered to, a 

housing unit during a given period of time. For the RECS tables and analyses, all expenditure statistics are 

presented on an annual basis. The total dollar amount includes state and local taxes but excludes merchandise, 

repairs, or special service charges. Electricity and natural gas expenditures are for the amount of those energy 

sources consumed. Fuel oil, kerosene, and liquefied petroleum gas expenditures are for the amount of fuel 

purchased, which may differ from the amount of fuel consumed. For households that do not pay their fuel 

supplier directly, the expenditures for fuels are estimated.
Page 23 GAO-12-848R Home Energy Assistance

Table 4: Average Energy Expenditures and Home Size for All Occupants of Manufactured, Detached, 

Attached, Apartments and All Homes by Year of Construction, 2005

Types of homes and year of 

construction

Average energy 

expenditures per 

square foot (in 

dollars)

Average annual 

energy expenditures 

(in dollars)

Average home size 

(in square feet)

Manufactured 

homes

Built 1979 and 

before

$1.75 $1,369 906

Built after 1979 1.54 1,583 1,158

Detached homes Built 1979 and 

before

0.92 1,996 2,631

Built after 1979 0.79 2,161 3,372

Attached homes Built 1979 and 

before

1.11 1,690 1,978

Built after 1979 0.84 1,482 2,182

Apartments Built 1979 and 

before

1.71 1,339 929

Built after 1979 1.27 1,053 943

All homes Built 1979 and 

before

1.14 1,802 2,133

Built after 1979 $0.97 $1,822 2,562

Source: GAO analysis of EIA’s RECS data.

Table 5: Average Energy Expenditures and Home Size for Occupants of Manufactured, Detached, 

Attached, Apartments for Homes of Any Age, 2005

Types of homes Average energy 

expenditures per square foot 

(in dollars)

Average annual energy 

expenditures (in dollars)

Average home size 

(in square feet)

All types of homes $1.07 $1,810 2,307

Manufactured homes 1.62 1,501 1,062

Detached homes 0.87 2,060 2,919

Attached homes 0.99 1,598 2,069

Apartments $1.54 $1,228 935

Source: GAO analysis of EIA’s RECS data.
Page 24 GAO-12-848R Home Energy Assistance

Table 6: Average LIHEAP Assistance by LIHEAP Recipients’ Type of Home and Year of Construction, 

2005

Average LIHEAP 

assistance (% energy 

expenditures)

Average LIHEAP 

assistance per square 

foot (in dollars)

Average annual LIHEAP 

assistance (in dollars)

All types of homes 21.89 $0.26 $302

Manufactured homes a 329 a

Detached homes 20.50 0.20 345

Attached homes 20.57 0.18 306

Apartments 23.74 0.32 230

All homes built in 1979 

or before

20.43 0.24 300

All homes built after 

1979

26.03 $0.30 $307

Source: GAO analysis of EIA’s RECS data.

a

Calculated value is not reliable because either (1) the relative standard error was less than 2, or (2) the number 

of observations used to calculate the mean estimate was less than 10.

Table 7: Percentage of Occupants with Income below 150 Percent of the Poverty Level by Housing Type 

and Year of Construction, 2005

Types of homes Percentage of occupants below poverty threshold

Manufactured homes

Built in 1979 and before 55.0

Built after 1979 42.0

All 47.0

Detached homes

Built in 1979 and before 23.5

Built after 1979 10.6

All 18.5

Attached homes

Built in 1979 and before 38.7

Built after 1979 22.5

All 31.6

Apartments

Built in 1979 and before 45.5

Built after 1979 39.4

All 39.4

Source: GAO analysis of EIA’s RECS data.
Page 25 GAO-12-848R Home Energy Assistance

Table 8: Average Energy Expenditures, Home Size, and Assistance for LIHEAP Recipients in 

Manufactured, Detached, Attached, and Apartment Homes, 2005 

Average 

energy 

expenditures 

per square 

foot (in 

dollars)

Average 

annual 

energy 

expenditures 

(in dollars)

Average 

home 

size (in 

square 

feet)

Average 

LIHEAP 

assistance 

(% energy 

expenditures)

Average 

LIHEAP 

assistance 

per square

foot (in 

dollars)

Average 

annual 

LIHEAP 

assistance 

(in dollars)

Manufactured 

homes

All $1.97 $1,708 946 a $329 a

Built 

in 

1979 

and 

before

2.02 1,386 710 19.60 $0.33 214

Detached 

homes

All 1.09 2,020 2,311 20.50 0.20 345

Attached 

homes

All 0.97 1,723 2,046 20.57 0.18 306

Apartments All 1.96 1,415 818 23.74 0.32 230

All homes Built 

in 

1979 

and 

before

1.44 1,831 1,757 20.43 0.24 300

Built 

after 

1979

$1.39 $1,541 1,428 26.03 $0.30 $307

Source: GAO analysis of EIA’s RECS data

a

Calculated value is not reliable because either (1) the relative standard error was less than 2, or (2) the number 

of observations used to calculate the mean estimate was less than 10.

Table 9: Average Energy Expenditures, Home Size, and Assistance for LIHEAP Recipients in All Housing 

Types in Rural and Nonrural Areas, 2005

Average 

energy 

expenditures 

per square 

foot (in 

dollars)

Average

annual 

energy 

expenditures 

(in dollars)

Average 

home 

size (in 

square 

feet)

Average 

LIHEAP 

assistance 

(% energy 

expenditures)

Average 

LIHEAP 

assistance 

per square 

foot (in 

dollars)

Average 

annual 

LIHEAP 

assistance 

(in dollars)

Rural $1.07 $1,761 2,235 20.56 $0.24 $288

Non-rural $1.07 $2,005 2,595 a $376 a

Source: GAO analysis of EIA’s RECS data.

Note: The U.S. Census Bureau defines homes as rural if they are located outside of core census block groups or 

blocks that have a population density of at least 1,000 people per square mile and surrounding census blocks 

that have an overall density of at least 500 people per square mile. However, 2005 RECS figures on rural and 

nonrural homes are based on respondents reporting whether they live in a rural or nonrural area on the survey.

a Calculated value is not reliable because either (1) the mean of each variable divided by its standard error was 

less than 2, or (2) the number of observations used to calculate the mean estimate was less than 10.
Page 26 GAO-12-848R Home Energy Assistance

Table 10: Average Annual LIHEAP Assistance by Annual Household Income Ranges, 2005

Annual income ranges

Average annual 

LIHEAP assistance 

(in dollars)

Less than $5,000 $298

$5,000 to $7,499 250

$7,500 to $9,999 318

$10,000 to $14,999 262

$15,000 to $19,999 364

$20,000 to $24,999 310

$25,000 to $29,999 301

$30,000 to $34,999 382

$35,000 or more $314

Source: GAO analysis of EIA’s RECS data.
Page 27 GAO-12-848R Home Energy Assistance

Enclosure IV: GAO Contact and Staff Acknowledgments

GAO Contact 

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

Staff Acknowledgments 

In addition to the individual named above, key contributors to this report were Jon 

Ludwigson, Assistant Director; Michael Kendix; Alison O’Neill; Kelly Rubin; James W. 

Turkett; and Jarrod West. Important assistance was also provided by Jonathan Kucskar, 

Armetha Liles, and Christine San.

(361352)
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