LIHEAP ELIGIBILITY Basic Enhanced Best Practice Barriers CLIENT ADDRESS GOAL: ENSURE CLIENT ADDRESS IS VALID AND MATCHES ENERGY PROVIDER INFORMATION Strategy Applicant provides home energy address on application and address documentation. Applicant provides home energy address on application and address documentation. Address is validated with vendor when possible. Applicant provides home energy address on application and address documentation. Address is validated with vendor when possible. Use data system to standardize address and check for duplicate addresses e.g. CD1P and Pitney Bowes. • non-standardized address • rural addresses • no systems in place • vendor cooperation Initial Cost low moderate moderate - high Operational Cost low moderate low - moderate Client Impact low low low HOME ENERGY OBLIGATION GOAL: ENSURE HOUSEHOLD HAS RESPONSIBILITY FOR HOME ENERGY Strategy Applicant provides energy bill or other proof and documentation of energy responsibility. Applicant provides energy bill or other proof and documentation of energy responsibility. Validate household account with vendor. Applicant provides energy bill or other proof and documentation of energy responsibility. Validate household account with vendor. Automated account verification as much as possible prior to payment. • energy vendor partnership • IT systems • lack of current policy • lack of funding • public utility policies • client cost Initial Cost low moderate high Operational Cost low moderate moderate Client Impact moderate moderate moderate
FISCAL MANAGEMENT GOAL: ENSURE THAT ALL LIHEAP FUNDS ARE PROPERLY SPENT AND ACCOUNTED FOR STATE FISCAL CONTROLS GOAL: POLICIES AND PROCEDURES IN PLACE TO PROPERLY SPEND AND TRACK ALL PROGRAM FUNDS Basic Enhanced Best Practice Barriers LOCAL AGENCY PROCESSES, SYSTEMS, CONTROLS GOAL: GUIDELINES, POLICIES AND PROCEDURES IN PLACE TO PROPERLY SPEND AND TRACK ALL PROGRAM FUNDS Strategy Require contract (or state regulations) with local agencies that establishes rights and responsibilities of local agencies and ensures that they follow generally accepted accounting principles and have an appropriate financial audit. Require contract (or state regulations) with local agencies that establishes rights and responsibilities of local agencies and ensures that they follow generally accepted accounting principles and have an appropriate financial audit. Require each local agency to develop detailed plan for fulfilling responsibilities. Require contract (or state regulations) with local agencies that establishes rights and responsibilities of local agencies and ensures that they follow generally accepted accounting principles and have an appropriate financial audit. Require local agency to develop a comprehensive local plan for fulfilling responsibilities that details internal training, evaluation, monitoring, and technical assistance as needed. • local capacity • fiscal and management skills • time • centralized systems • funding • expertise in contracting • conflict of interest • lack of T&TA funding • funding not timely or consistent Initial Cost low - moderate moderate moderate - high Operational Cost low - moderate low - moderate moderate - high Client Impact low low low
OVERSIGHT GOAL: ENSURE COMPLIANCE WITH FEDERAL AND STATE LIHEAP GUIDELINES Basic Enhanced Best Practice Barriers STATE MONITORING of SUBGRANTEES GOAL: ENSURE SUBGRANTEE COMPLIANCE WITH FEDERAL, STATE GUIDELINES, POLICY/ PROCEDURES Strategy Periodic data review and desk or on-site monitoring every three years of every subgrantee and review of annual single audits. Ongoing data review and annual risk assessment of every subgrantee to determine if on-site monitoring is required. Ongoing monitoring process of subgrantees with an annual on-site monitoring of every subgrantee using an information system that supports the monitoring process. • cost • staff • data system • staff training • travel requirements Initial Cost low - moderate moderate high Operational Cost low - moderate moderate high Client Burden low low low TRAINING GOAL: ENSURE ALL STAKEHOLDERS ARE AWARE OF AND UNDERSTAND POLICIES, PROCEDURES, STATUTES AND CONTRACTUAL REQUIREMENTS Strategy Written policies developed and distributed annually or more often as needed. Written policies developed and distributed annually or more often as needed. Notify of program changes by conducting training sessions such as webinars. Written policies developed and distributed annually or more often as needed. Notify of program changes by conducting training sessions such as webinars. Conduct face to face and on-site visits annually or more frequently as needed. • staff • resource allocations • expertise in policy and statute procedures and contracts • lack of stakeholder participation or consensus Initial Cost moderate - high moderate moderate - high Operational Cost low moderate high Client Burden low low low
OVERSIGHT Basic Enhanced Best Practice Barriers ONGOING DATA REVIEW FOR ANOMALIES GOAL: PROACTIVELY IDENTIFY POTENTIAL AREAS FOR FRAUD OR RISK OF FRAUD Strategy Periodic data review of subgrantees and desk or on-site monitoring every year. Ongoing data review of subgrantees to determine if on-site monitoring is required. Ongoing data review of subgrantees with annual monitoring. • cost • staffing • adequate data systems • skill set • lack of protocols and procedures Initial Cost high high high Operational Cost moderate moderate - high high Client Burden low low low INTERNAL CONTROL FRAMEWORK (ICF) GOAL: ENSURE SYSTEMS CAN IDENTIFY, ANTICIPATE AND PREVENT RISK TO PUBLIC RESOURCES Set of standard operating procedures in line with applicable OMB circulars. Set of standard operating procedures in line with applicable OMB circulars. Comprehensive ICF that has Committee of Sponsoring Organizations (COSO) standards. Set of standard operating procedures in line with applicable OMB circulars. Comprehensive ICF that has COSO standards. ICF is regularly reviewed and updated. • support of leadership • funding • resources and staffing • acquiring knowledge Initial Cost low - moderate high moderate Operational Cost low moderate high Client Burden low low low
OVERSIGHT Basic Enhanced Best Practice Barriers ENERGY VENDOR OVERSIGHT GOAL: ENSURE VENDOR PERFORMANCE THROUGH DOCUMENTATION AND MONITORING Strategy Signed vendor agreement or written assurance that vendor is providing equitable benefits and service delivery. Signed vendor agreement or written assurance with occasional vendor monitoring and documentation that vendor is providing equitable benefits and service delivery. Signed vendor agreement or written assurance with regular vendor monitoring and documentation that vendor is providing equitable benefits and service delivery with additional documentation. • large number of vendors • small vendors • staff resources • capacity and capability • lack of vendor offices to monitor • politics • vendor participation Initial Cost moderate - high moderate high Operational Cost moderate moderate high Client Burden low low low CONFIDENTIALITY AND DATA SECURITY GOAL: ENSURE SECURITY OF ALL SYSTEMS AND DATA THEREIN Strategy Maintain a secure system with written procedures on sharing and handling confidential data, signed security agreements and password protection (where applicable); meets industry standards. Maintain a secure system with written procedures on sharing and handling confidential data, signed security agreements and password protection (where applicable); meets industry standards. Each grantee and subgrantee has written plan for managing data security. Maintain a secure system with written procedures on sharing and handling confidential data, signed security agreements and password protection (where applicable); meets industry standards. Each grantee and subgrantee has written plan for managing data security. Grantee monitors data security. • technical expertise • funding • lack of HHS policy • maintaining agreements • staff turnover Initial Cost high high high Operational Cost moderate moderate high Client Burden low low low