Arkansas Administrative Code › Agency 016 - DEPARTMENT OF HUMAN SERVICES › Division 20 - Division of County Operations › Rule 016.20.16-004 - FFY 2017 Low Income Home Energy Assistance Program (LIHEAP)

Current through Register Vol. 49, No. 6, June, 2024
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FFY 2016-2017 PLAN ATTACHMENTS
Ms. Lauren Christopher, Director
Division of Energy Assistance
Office of Community Services
U.S. Department of Health and Human Services
370 L'Enfant Promenade, S.W.
Washington, DC 20447
Dear Ms. Christopher:
As Governor of the State of Arkansas, I am delegating authority
				to the Assistant Director of the DHS Division of County Operations/Office of
				Community Services to sign the Department of Human Services Low-Income Home
				Energy Assistance Program (LIHEAP) Assurances for the FY 2017 LIHEAP State
				Plan.
If you have any questions or concerns, please contact Ms. Lorie
				Williams, DCO Assistant Director, Arkansas Department of Human Services, at
				(501) 682-8714. We appreciate your partnership and continued support.
Thank you for your attention to this matter.
FFY 2016-2017
BENEFIT MATRIX WINTER HEATING PROGRAM
Countable Income
(1
Sc
						  2)
(3 & 4)
(5 & Above)
0-69 70-129
218 209
259 248
309 299
130-189 190-249
198 188
239 229
289 278
250-309 310-369
179 168
218 209
269 259
370-429 430-489
161 156
200 193
248 239
490-549 550-609
153 149
188 183
229
218
610-669 670-729
144 139
177 173
209 198
730-789 790-849
134 129
168 163
188 179
850-909 910-969
124 119
158 153
170 164
970-1029 1030-1089
114 109
148 143
159 153
1090-1149 1150-1209
104 99
138 133
148 142
1210-1269 1270-1329
94 90
128 123
137 131
1330-1389 1390-1449
86 82
118 113
126 121
1450-1509 1510-1569
79 76
108 103
116 111
1570-1629 1630-1689
73 70
98 93
106 101
1690-1749 1750-1869
67 64
88 83
96
91
1870-1989 1990-2009
60 56
78 73
86 81
2010-2129 2130-2249
68 63
76 71
2250-2369 2370-9907
58 53
66 61
NOTE: Any household with five or more members will receive the
				payment amount in the far right column marked five and above on MCI.
FFY 2016-2017
BENEFIT MATRIX SUMMER COOLING PROGRAM
Countable Income
(1 & 2)
(3 & 4)
(5 & Above)
0-69 70-129
218 209
259 248
309 299
130-189 190-249
198 188
239 229
289 278
250-309 310-369
179 168
218 209
269 259
370-429 430-489
161 156
200 193
248 239
490-549 550-609
153 149
188 183
229 218
610-669 670-729
144 139
177 173
209 198
730-789 790-849
134 129
168 163
188 179
850-909 910-969
124 119
158 153
170 164
970-1029 1030-1089
114 109
148 143
159 153
1090-1149 1150-1209
104 99
138 133
148 142
1210-1269 1270-1329
94
90
128 123
137 131
1330-1389 1390-1449
86 82
118 113
126 121
1450-1509 1510-1569
79 76
108 103
116 111
1570-1629 1630-1689
73 70
98 93
106 101
1690-1749 1750-1869
67 64
88 83
96 91
1870-1989 1990-2009
60 56
78 73
86 81
2010-2129 2130-2249
68 63
76
71
2250-2369 2370-9907
58 53
66
61
NOTE: Any household with five or more members will receive the
				payment amount in the far right column marked five and above
on
MCI.
CONTACT PERSON: Shirley Mason
NOTICE OF RULEMAKING AND PUBLIC HEARING
The Department of Human Services, Division of County
				Operations, intends to adopt a State Plan for distribution of Low-Income Home
				Energy Assistance Program (LIHEAP) Block Grant funds and administration of the
				Home Energy Assistance Program, for Federal Fiscal Year 2017, covering the
				period from October 1, 2016 to September 30, 2017. Arkansas administers the
				LIHEAP Block Grant under Public Law 97-35, as amended. Funding is expected to
				be approximately $27,000,000.00.
The draft State Plan for LIHEAP is available for review at the
				Home Energy Assistance Program office on the 3rd floor of Donaghey Plaza South,
				Seventh and Main Streets, in Little Rock, during business hours, 8:00 a.m. to
				4:30 p.m., or copies may be obtained by contacting the Office of Community
				Services at (501) 682-8715. You may also access it on the DHS website
				http:humanservices.arkansas.gov/Pages/LegalNotices.aspx. All comments must be
				submitted in writing to the address indicated above no later than July 30,
				2016.
Those who wish to comment on the proposed plan may attend the
				public hearing closest to you or you may comment in writing to the state agency
				listed below. All comments must be submitted no later than 30 days from the
				date of this newspaper notice to:
Division of County Operations
ATTN: Office of Community Services/HEAP
				Unit
Post Office Box 1437, S330 Little Rock, Arkansas
				72203
Arkansas Department of Human
				Services
Division of County Operations/Office of Community
				Services
Public Comment Report - Arkansas Low Income Energy
				Assistance State Ptan (LIHEAP)
Public Hearings
The Low Income Home Energy Assistance Program (LIHEAP) staff
				and the Assistant Director of the Arkansas Department of Human
				Services/Division of County Operations/Office of Community Services conducted
				four public hearings. The public hearings informed the public of the upcoming
				submission of the LIHEAP State Plan and key facts regarding the administration
				and operations of the FY 2016-2017 LIHEA Program. Comments and concerns were
				expressed regarding the activities currently considered as Administrative
				Costs.
Legal notices were published in the Arkansas Democrat - Gazette
				for three (3) consecutive days, July 1-3, 2016. The 2016-2017 Low Income Home
				Energy Assistance Program State Plan was made available for public inspection
				and comments for 30 days (July 1-30, 2016).
Those who wished to comment could respond orally at the Public
				Hearing or submit written comments to the DHS/DCO Office of Community
				Services.
July 11,2016 - Springdaie,
				Arkansas
The Public Hearing was conducted by Shirley Mason, LIHEAP
				Program Manager and Lorie Williams, Assistant Director.
Three people attended the Public Hearing. Each person was
				provided an agenda and a copy of the State Plan Summary. Upon completion of the
				oral presentation by the representatives from the DHS/OCS, those attending were
				invited to ask questions and to make comments.
During the Public Hearing, there were no comments regarding the
				LIHEAP State Plan. However, there were concerns regarding the administration of
				the LIHEAP Program funds.
Questions were asked by Blain Lawrence, LIHEAP Coordinator OOI,
				Audra Butler, COO, ARVAC, and Casey Beavers, LIHEAP Coordinator EOAWC.
Question #1:
Audra Butler
Can A-16 funds be transferred into the Crisis Program if
				agencies opt-out of the A-16 program? Response; Yes.
Question #2:
Blain Lawrence
Can LIHEAP Program Funds be used to pay direct program expense
				such as salaries for case managers, program supplies, etc.?
Response by State Agency
Lorie Williams and Shirley Mason
It was explained to the attendees that the allocation for the
				administration of the LIHEAP program is a maximum of 10% per Federal
				regulations and that percentage cannot be increased.
The State Agency, however, will review the activities currently
				being considered as Administrative cost and determine if changes can be
				made.
July 12,2016
-
BatesviHe,
				Arkansas
The Public Hearing was conducted by Shirley Mason, LIHEAP
				Program Manager and Lorie Williams, Assistant Director.
Six people attended the Public Hearing. Two out of the six were
				private CPAs. The remaining four were from the Community Action Agencies. Each
				person was provided an agenda and a copy of the State Plan Summary. Upon
				completion of the oral presentation by the representatives from the DHS/OCS,
				those attending were invited to ask questions and to make comments.
During the Public Hearing, there were no comments regarding the
				LIHEAP State Plan. However, there were concerns regarding the administration of
				the LIHEAP Program funds.
Questions were asked by Kathy Ruminer, LIHEAP Coordinator,
				NADC, Staci Albert, NADC, Charlie Morris, Director, NADC, Ron Cantrell, Marie
				Thorn, NADC, and John Welch,
Question #1:
Staci
				Albert
Can you take $300 + $500 to pay the Crisis bill?
Response by State Agency
Shirley Mason
Benefits from Regular Assistance and Crisis Intervention may be
				coordinated.
Question #2
Kathy
				Ruminer
What determines life-threatening for Crisis?
Response by State Agency
Shirley Mason
A life threatening event would be one that could prove fatal
				for a household in the event there was a loss of energy. This type of
				determination is often accompanied by a written statement from a certified
				medical professional.
Question #3
Ron Cantrell
Is the LIHEAP Allocation a 2-tier test based on the previous
				funding and the number of low-income person?
jesponse by State Agency
Shirley
				Mason
The LIHEAP allocation is based on the US Census Data and
				Poverty Rates for each county. We are currently reviewing that information to
				update from the latest US Census Data.
Question 4
John Welch
Is funding stagnated for ten years?
Response by State Agency
Shirley
				Mason
The LIHEAP funding allocation Distribution formula has
				not been changed in several years. We are currently reviewing that information
				to update from the latest US Census Data.
Question #5
Charlie Morris Is
				the entire funding for weatherization funded through one entity? (Department of
				Energy) Is the entire funding for weatherization funded through one entity?
				(Department of Energy) weatherization?
Response by State Agency
Shirley
				Mason
The Arkansas Department of Energy is the Sub-grantee for
				LIHEAP Weatherization funds. For information on becoming a sub-contractor for
				LIHEAP WAP, you may contact the Weatherization Section at the Arkansas
				Department of Energy.
Question #6:
Charlie Morris Can
				LIHEAP Program Funds be used to pay direct program expense such as salaries for
				case managers, program supplies, etc.?
Response by State Agency
Lorie
				Williams and Shirley Mason
It was explained to the attendees the allocation for the
				administration of the LIHEAP program is a maximum of 10% per Federal
				regulations and cannot be increased.
The State Agency, however, will review the activities
				currently being considered as Administrative cost and determine if changes can
				be made.
July 13,2016 - Prescott,
				Arkansas
The Public Hearing was conducted by Shirley Mason, LIHEAP
				Program Manager and Lorie Williams, Assistant Director.
Two people attended the Public Hearing. Each person was
				provided an agenda and a copy of the State Plan Summary. Upon completion of the
				oral presentation by the representatives from the PHS/OCS, those attending were
				invited to ask questions and to make comments.
During the Public Hearing, there were no comments regarding the
				LIHEAP State Plan. However, there
were concerns regarding
the
administration
of
the LIHEAP Program funds.
Questions were asked by Todd Anderson, LIHEAP Program
				Director, CADC, and Jim McPhaul, Executive Director, SWADC.
Question
#1:
Todd Anderson
Can LIHEAP Program Funds be used to pay direct program expense
				such as salaries for case managers,
program supplies, etc.?
Response: The State Agency, however, will review the activities
				currently being considered as Administrative cost and determine if changes can
				be made.
Question
#2:
Jim McPhaul
Any Idea regarding the time frame that we receive notification
				regarding admin program cost?
Response: OCS will have to make an assessment and present it to
				the Division Director for review.
Juiy 14,2016 - Warren,
				Arkansas
The Public Hearing was conducted by Shirley Mason, LIHEAP
				Program Manager and Lorie Williams, Assistant Director.
Five people attended the Public Hearing. Each person was
				provided an agenda and a copy of the State Plan Summary. Upon completion of the
				oral presentation by the representatives from the DHS/OCS, those attending were
				invited to ask questions and to make comments.
During the Public Hearing, there were no comments regarding the
				LIHEAP State Plan. However, there were concerns regarding the administration of
				the LIHEAP Program funds.
Questions were asked by Alethea Dallas, Interim Director,
				SEACAC.
Questions #1 and #2:
Alethea
				Dallas, Interim Executive Director, SEACAC
Define Administration and Program Cost?
Response: Because the LIHEAP Program is a block grant, there
				are certain activities that can be allowed either under Administrative or as
				Program. We understand that the Community Action Agencies would like for the
				State to review the current activities and determine if some can now be
				considered as
Program Costs. The State Agency will review the activities
				currently being considered as Administrative cost and determine if changes can
				be made.
Is there any flexibility with Administration Cost vs Program
				Cost?
Response: The State Agency will review the activities currently
				being considered as Administrative cost and determine if changes can be
				made.
Written
Comments
The agency received seven written comments. All but one was
				related to the activities allowed in Administrative and Program Costs. The
				other was concerning the allocation for each agency and how that is determined.
				(See Attachment I).
A written response to those comments was issued by the
				DHS/Office of Community Services (See Attachment II).
NPO BUILDERS, LLC
185 MILL RUN TRL
BATESVILLE, AR 72501
(870) 307-5264
July 13, 2016
Division of County Operations HEAP Unit
P.O. Box 1437, Slot S-330 Little Rock, AR 72203
RE: HEAP Public Hearing Comments
To Whom It May Concern:
I appreciate Ms. Williams and Ms. Mason for visiting Batesville
				and presenting the HEAP program information and listening to various comments
				and suggestions from local residents. In accordance with the request for
				comments, I'd like to offer the following.
I'm a CPA as well as a Certified Financial Planner, and a
				Certified Fraud Examiner. My experience since 1980 has been almost exclusively
				intertwined with both nonprofits that receive governmental grant funding, and
				governmental organizations or sub-units. This experience includes audit,
				consulting, or volunteer work with at least 5 of the State's Community Action
				organizations. I've also served as a CFO/Treasurer for one of Arkansas' larger
				retailers and a couple of govemmentally-funded nonprofits.
My experiences at these, and other nonprofits, has shown that
				there are apparently some serious challenges for the CAPs fiscally to remain
				solvent, viable, and robust. Some have seen their financial positions
				deteriorate dramatically over the past decade, almost to the point of closing
				their doors. More certainly some have had to curtail various programs and
				services, cut staff, and as a result shrink their ability to consider further
				growth and service opportunities.
I only mention this because with relative ease, the DCO,
				specifically HEAP policy, can make a profound and positive impact moving
				forward for these community service providing agencies.
Comment #1
At this time HEAP direct line client service staff and their
				related costs are considered to be "administrative" and are subject to a very
				limited funding allocation within each CAP'S HEAP budget.
While not subject to the OMB Omnicircular*s 10% de minimus
				overhead rate, that rate might be considered to establish what federal
				officials considered a bare but reasonable level for administrative costs. Some
				grants allow the 10% (or more) overhead to flow down to the subrecipiertt level
				but such is not the case with HEAP subrecipients. Since the total
				administrative costs for ALL levels of program services is 10%, the
				subrecipients, after the State takes its needed administrative portion, are
				left with an extraordinarily low level of funding to cover both its {1)
				indirect administrative costs and (2) the costs for direct service staff, which
				includes Case Management and Outreach.
To illustrate, for one of the Agencies I serve, the average
				"Indirect" or pure administrative allocation allowed was only 2.49% for FY
				2014, and 1.16% for FY 2015! The rest of their small administrative share was
				made up of direct line service staff and related costs. Since Indirect'* costs
				have to be allocated proportionately, you can see the situation is quite
				challenging.
"Helping Nonprofits Manage Their Finances, Master Their
				Minims*
According to IM 2000-12, as well as a LiHeap Clearinghouse
				Issue Brief dated June, 2014, it is not necessary for the State to consider
				outreach and case management activities as administrative. The Issue Brief
				indicates that Illinois, Indiana, and Washington consider outreach, case
				management, budget counseling, energy education, vendor negotiations to be
program
, not administrative costs. IM 2000-12 reminds
				the States that they have a great deal of flexibility, within TANF general
				guidelines, to structure programs as they feel work best for themselves.
In order for the CAPs to improve their viability and strength,
				I recommend the State redefine its administrative component to specifically
				exclude case management and outreach activities performed for the HEAP program.
				I am not asking for an increase of the 10% admin cost ceiling from either the
				State or Federal government. I am asking only that a small portion of the
				utility assistance funds be redirected to another allowable
program
cost component - Case Management and/or
				Outreach (or similar).
Attached are both documents for your review.
I hope you will give very serious and thoughtful consideration
				to this change. Alhough small for the HEAP program as a whole, such a change
				would be extremely meaningful to each individual Community Action Agency. It
				would not be a windfall by any means, but a meaningful tweak to their fiscal
				health and structure.
Comment #2
Regarding the way that HEAP funds are distributed to the
				State's subrecipient Community Action Agencies, I hope that the awards are
				based on current population statistics for low-income persons, rather than
				statistics that are up to a decade old. There are resources available for
				reliable estimates annually from the most recent US census, UALR, etc., and
				perhaps those could be used to ascertain the poverty rates used to determine
				the allocations of HEAP funds to each CAP. As populations shift, it is possible
				that continued high funding could be made for areas where poverty is in decline
				relative to other areas where poverty is growing. Naturally, areas where
				poverty is growing, is where HEAP funds should be increased. Leaving high
				funding in areas where poverty rates are decreasing relative to others is, at
				least anecdotally, harmful to the areas where people in poverty numbers are
				growing and they should not be penalized with lower than average funding
				availability.
Again, I hope you might take a close look at the allocation
				issue as well in order to be sure that it meets the needs of the communities on
				a current basis.
July 19, 2016
Division of County Operations HEAP Unit
P.O. Box 1437, Slot S-330 Little Rock, AR 72203
RE: HEAP Public Hearing Comments
To Whom It May Concern:
I would like to follow up to my earlier letter responding to
				your request for public comments regarding the HEAP program as follows:
Transparency
Regarding how the LiHeap funds are distributed state-wide to
				each community action organization, I believe it is important to have
				transparency in the distribution model.
Since the methodology, math, source data, etc. are all
				available under the Freedom of Information Act, it would seem to be extremely
				helpful if the State would simply provide the allocation details when the award
				amounts are distributed each year to the CAP agencies.
The population statistics for persons in poverty can be made
				available by county and show the specific way these statistics are used to
				determine what share of the State's total funding is made available to each
				Agency, as well as the State's share of the 10% administrative portion coming
				out of the CAP Agency totals.
I am led to believe there has been frustration in various
				efforts to discover this information in the recent past.
Ron Cantrell NPO Builders, LLC 185 Mill Run TRL Batesville,
				Arkansas 72501
Dear Mr. Cantrell:
Thank you for your comments regarding the LIHEAP State Plan. In
				response to your question regarding the activities currently being allowed in
				Administration and Program, the agency will review the activities and determine
				if any changes can be made. Upon completion of the review the assessment will
				be provided to the Division Director for review. In addition, the State will
				discuss with the Community Action Agencies the process of how the allotments
				are determined.
If you have any questions, please contact Shirley Mason, HEAP
				Manager at (501) 682-8726.
Division of County Operations HEAP Unit
P.O. Box 1437, Slot S-330 Little Rock, AR 72203
RE: HEAP Public Hearing Comments
To Whom It May Concern:
I attended a recent public hearing about the HEAP program in
				our area and I'd like to offer the following in response.
As a CPA in the business of helping nonprofits be successful,
				and particularly with my experience working with Community Action Agencies all
				over the State of Arkansas, I am concerned about their general financial health
				and well-being. It seems that many of them are struggling, facing very tough
				times, and having to make decision about cutting programs and services in the
				areas they serve.
After attending the public hearing in Batesville, I am led to
				believe that there is something very important that the State leadership could
				actually accomplish with very little relative effort, and make a really
				tremendous impact on these organizations that serve the mission of Congress and
				the State.
At this time HEAP direct line client service staff and their
				related costs are considered to be "administrative". Since the total
				administrative costs for ALL levels of program services is 10% including the
				State's share, the sub-recipients i.e. the
CAP
Agencies
are
left with very little funding to cover both its indirect
				administrative costs and the costs for direct service staff, who's
				functionality includes both outreach and case management services. Those two
				services, according to IM 200-12 do not need to be counted towards the
				administrative component.
According to IM 2000-12, as well
as a
LiHeap
				Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State
				to consider outreach and case management activities as administrative. The
				Issue Brief indicates that several other states consider outreach, case
				management, and other areas of service to be
program
costs. IM 2000-12 reminds the States that they have a great deal of flexibility
				in the design of their HEAP program.
I sincerely hope the State will redefine "administration" to
				exclude case management and outreach activities performed for the HEAP program.
				The mechanics of such a change would be to move a small portion of the utility
				assistance funds (2.75%, for example) be redirected to another allowable
				program cost component which would be something like Case Management and/or
				Outreach whatever name the State prefers. This level of increase would bring
				the total for non-utility assistance expenses, excluding Assurance 16 to about
				10%, which seems to me to be a great value for the State of Arkansas.
I hope you will give the suggestion very serious and thoughtful
				consideration. It could make the world of difference to the Agencies entrusted
				to perform the services OCS asks them to.
John Ed Welch
Welch, Couch & Company, PA
P.O. Box 2094
Batesville, Arkansas 72503
Dear Mr. Welch:
Thank you for your comments regarding the LIHEAP State Plan. In
				response to your question regarding the activities currently being allowed in
				Administration and Program, the agency will review the activities and determine
				if any changes can be made. Upon completion of the review the assessment will
				be provided to the Division Director for review.
If you have any questions, please contact Shirley Mason, HEAP
				Manager at (501) 682-8726.
July 14, 2016
HEAP Unit
P.O. Box 1437, Slot S-330
Little Rock, Ar. 72203
RE: HEAP Public Hearing Comments
To
Whom It May Concern:
I attended a recent public hearing about the HEAP program in
				our area and I'd like to offer the following response.
As a resident concerned about the health of the Community
				Action Agency in our area, I am concerned about their general financial health
				and well-being.
After attending the public hearing locally, I am led to believe
				that there is something very important that the state leadership could actually
				accomplish with very little relative effort, and make a really tremendous
				impact on these organizations that serve the mission of Congress and the
				State.
At this time HEAP direct line client service staff and their
				related costs are considered to be "administrative". Since the total
				administrative costs for ALL levels of program services is 10% including the
				State's share, the subrecipients i.e. the CAP Agencies
are
left with very little funding to cover both its indirect
				administrative costs and the costs for direct service staff, who's
				functionality includes both outreach and case management services. Those two
				services, according to IM 200-12 do not need to be counted towards the
				administrative component.
According to IM 2000-12, as well as a LiHeap Clearinghouse
				Issue Brief dated June, 2014, it is not necessary for the State to consider
				outreach and case management activities as administrative. The Issue Brief
				indicates that several other states consider outreach,
case
management, and other areas of service to be
program
costs. IM 2000-12 reminds the States that they
				have a great deal of flexibility in the design of their HEAP program.
I sincerely hope the State will reconsider its definition of
				"administration" to
exclude
case management and
				outreach activities performed for the HEAP program.
I hope you will give the suggestion very serious and thoughtful
				consideration. It could make the world of difference to the Agencies entrusted
				to perform the services OCS asks them to do.
Augusts, 2016
Mollie Everett
Crowley's Ridge Development Council, Inc.
2401 Fox Meadow Lane
Jonesboro, Arkansas 72403
Dear Ms. Everett:
Thank you for your comments regarding the LIHEAP State Plan. In
				response to your question regarding the activities currently being allowed in
				Administration and Program, the agency will review the activities and determine
				if any changes can be made. Upon completion of the review the assessment will
				be provided to the Division Director for review.
If you have any questions, please contact Shirley Mason, HEAP
				Manager at (501) 682-8726.
July 18, 2016
Ms. Lorie Williams, Assistant Director
Division of County Operations
HEAP Unit
PO Box 1437, Slot S-330
Little Rock, AR 72203
RE: HEAP Public Hearing Comments
Dear Lorie:
I heard about the recent public hearing about the HEAP program
				in Batesville and I'd like to offer the following response.
As the Executive Director of a Community Action Agency in our
				area, I am concerned about the general financial health and well-being and
				sustainability of these agencies.
After hearing testimony at the public housing, I am led to
				believe that there is something very important that the state leadership could
				accomplish with very little effort, and make a real impact on these
				organizations that serve the mission of Congress and the State.
At this time HEAP direct line client service staff and their
				related cost are considered to be "administrative". Since the total
				administrative cost for ALL levels of program services is 10% including the
				State's share, the subrecipients i.e. the CAP Agencies are left with very
				little funding to cover both its indirect administrative costs and the cost for
				direct service staff, who's functionality includes both outreach and case
				management services. Those two services, according to IM 200-12 do not need to
				be counted towards administrative component.
According to IM 200-12, as well as a LiHeap Clearinghouse Issue
				Brief dated June, 2014, it is not necessary for the State to consider outreach
				and case management activities as administrative. The Issue Brief indicates
				that several other states consider outreach, case management, and other areas
				of service to be
program
costs. IM 200-12 reminds the
				States that they have a great deal of flexibility in the design of their HEAP
				program.
Click here
				to view image
August 5, 2016
Tim Wooldridge
Crowley's Ridge Development Council, Inc.
2401 Fox Meadow Lane
Jonesboro, Arkansas 72403
Dear Mr. Wooldridge:
Thank you for your comments regarding the LIHEAP State Plan. In
				response to your question regarding the activities currently being allowed in
				Administration and Program, the agency will review the activities and determine
				if any changes can be made. Upon completion of the review the assessment will
				be provided to the Division Director for review.
If you have any questions, please contact Shirley Mason, HEAP
				Manager at (501) 682-8726.
July 18, 2016
Division of County Operations HEAP Unit
P.O. Box 1437, Slot S-330 Little Rock, AR 72203
RE: HEAP Public Hearing Comments
To Whom It May Concern:
I attended the recent public hearing about the HEAP program in
				Batesville and I'd like to offer the following in response.
As Executive Director of Northcentral Arkansas Development
				Council (NADC), managing a community action agency is very difficult with very
				limited revenue streams. I am concerned about our general financial health and
				well-being as I know many of my fellow executive directors with their agencies
				are as well. We all have our struggles, facing very tough times, and having to
				make decision about cutting programs and services in the areas we serve.
After attending the public hearing in Batesville, I am led to
				believe that there is something very important that the State leadership could
				actually accomplish with very little relative effort, and make a really
				tremendous impact on our organizations that serve the mission of Congress and
				the State.
At this time HEAP direct line client service staff and their
				related costs are considered to be "administrative". Since the total
				administrative costs for ALL levels of program services is 10% including the
				State's share, the subrecipients i.e. the CAP agencies are left with very
				little funding to cover both its indirect administrative costs and the costs
				for direct service staff, who's functionality includes both outreach and case
				management services. Those two services, according to IM 200-12 do not need to
				be counted towards the administrative component. To simplify the situation, one
				of my fellow directors said "it likes you have $100, out of that $100, $90 goes
				to the client, and the other $10 goes toward the outreach worker time and
				effort, paperwork, overhead, accounting, HR, etc. It is too tight of a
				margin."
According to IM 2000-12, as well as a LiHeap Clearinghouse
				Issue Brief dated June, 2014, it is not necessary for the State to consider
				outreach and case management activities as administrative. The Issue Brief
				indicates that several other states consider outreach, case management, and
				other areas of service to be
program
costs. IM 2000-12
				reminds the
States that they have a great deal
of flexibility in the design
of their HEAP
				program.
I sincerely hope the State will redefine "administration" to
				exclude case management and outreach activities performed for the HEAP program.
				The mechanics of such a change would be to move a small portion of the utility
				assistance funds (2.75%, for example) be redirected to another allowable
				program cost component which would be something like Case Management and/or
				Outreach whatever name the State prefers. This level of increase would bring
				the total for non-utility assistance expenses, excluding Assurance 16 to about
				10%, which seems to me to be a great value for the State of Arkansas.
We did a calculation on how much more we could receive with the
				proposed change and it was in the mid $20,000 range. It is not a lot of money
				but it gives us a little more breathing room to operate our services. I am
				certain that other agencies with similar and higher allocations would
				appreciate that extra income as well.
And while on allocations, I would like to make another request
				on sharing your distribution model with each agency for transparency purposes
				so each agency has a clearer picture how our funds are determined and
				funded.
I hope you will give our suggestions very serious and
				thoughtful consideration. It could make the world of difference to us in
				performing the services OCS asks of us.
August 5, 2016
Charlie Morris
Northcentral Arkansas Development Council, Inc.
P.O. Box 3349
Batesville, Arkansas 72503
Dear Mr. Morris:
Thank you for your comments regarding the LIHEAP State Plan. In
				response to your question regarding the activities currently being allowed in
				Administration and Program, the agency will review the activities and determine
				if any changes can be made. Upon completion of the review the assessment will
				be provided to the Division Director for review.
If you have any questions, please contact Shirley Mason, HEAP
				Manager at (501) 682-8726.
July 20, 2016
Division of County Operations HEAP Unit
P.O. Box 1437, Slot S-330 Little Rock, AR 72203
To Whom It May Concern:
I recently attended a public hearing about the HEAP program for
				this region of the State of Arkansas and I became concerned about the general
				financial health of the Community Action Agency in general. 1 encourage the
				State leadership to take steps necessary to positively impact the Community
				Action Agency that serve the mission of Congress in the State of
				Arkansas.
At this time HEAP direct line client service staff and their
				related costs are considered to be "administrative". Since the total
				administrative costs for ALL levels of program services is 10% including the
				State's share, the sub recipients i.e. the CAP Agencies are left with very
				little funding to cover both its indirect administrative costs and the costs
				for direct service staff, who's functionality includes both outreach and case
				management services. Those two services, according to IM 200-12 do not need to
				be counted towards the administrative component.
According to IM 2000-12, as well as a LiHeap Clearinghouse
				Issue Brief dated June, 2014, it is not necessary for the State to consider
				outreach and case management activities as administrative. The Issue Brief
				indicates that several other states consider outreach, case management, and
				other areas of service to be
program
costs. IM
				2000-12 reminds the States that they have a great deal of flexibility in the
				design of their HEAP program.
I sincerely hope the State will reconsider its definition of
				"administration" to
exclude
case management and
				outreach activities performed for the HEAP program.
August 5, 2016
Rick Reed Rick Reed Company P.O. Box 2705 Batesville, Arkansas
				72501
Dear Mr. Reed:
Thank you for your comments regarding the LIHEAP State Plan. In
				response to your question regarding the activities currently being allowed in
				Administration and Program, the agency will review the activities and determine
				if any changes can be made. Upon completion of the review the assessment will
				be provided to the Division Director for review.
If you have any questions, please contact Shirley Mason, HEAP
				Manager at (501) 682-8726.