FISCAL OVERVIEW for EAP and Wx

Training Facilitated by

Lynell Westbrook Community Programs Manager – EAP & CSBG

& Ray Judy

Community Program Manager - Wx

October 7, 2014

LIHEAP UPDATE

Funding

Policy Updates

Propane Crisis Plan

Carryover Report(s)

Good Cause Waiver

Recapture and Redistribution of Fund &Requesting Additional Funds

New Claims Testing Process

Q & A

NEW EAP BUDGET NARRATIVEAdministrative Line ItemsEligibility (based on expenditures) 8.5%Program Support (total award) 3%Technology 2% Cannot Exceed 13.5%

Family Development (total award) 2%

Technology Enhancements Up to 2% of total awardTo support technology development or enhancements; must request prior approval and these funds are not an additional 2%

Energy EducationEnergy Education and Materials/Supplies Up to 3% of total award

Regular/Crisis AssistanceRegular AssistanceCrisis Assistance Must set aside 8% budget thru 3/15/15

Summer Cool ProgramSummer Cool Benefits Will not budget until after winter endsSummer Cool A/Cs

CONTRACTS AND BUDGETSContract Components

• Administration of Funds (Section 4)• Ineligible Expenses (Section 5)• File Retention Policy (Section 6)• Modifications (Recapture and reallocate funds) (Section 7)• Air Conditioner Distribution (Section 9)• Program Income (Section 15)• FFATA Reporting (Section 29)

Attachment A• Outlines the award amount• How costs are claimed

Blank Budget Form• Must be completed and returned with the signed contract

REIMBURSEMENT ISSUESFamily Development – “agencies are not providing the required documentation. Most are using the Actions Report similar to claims submitted for Energy Ed . For Payroll expenses back up detail is required.”

Expenses – “any expense that is $1000.00 or more requires backup to support it.  If the expenses is made up of smaller amounts that must be shown.” Petty Cash reimbursements – “backup required unless the expenses are identified.” A/C purchase – “backup required regardless of dollar amount.” Energy Ed materials and supplies – “backup required regardless of dollar amount.” Miscellaneous expense – “backup required if the expense is not identified.”

SUBMITTING BUDGET PROJECTIONSREASON FOR EAP BUDGET PROJECTIONS•New Technology Policy – Ensure Prior Approval•Propane Crisis Planning•Carryover Estimate Reporting

EAP PROGRAM CARRYOVER

The State Program is allowed to carryover up to 10 percent of the total award.

FY2015 EAP Budget Projection Schedule•February 2015•April 2015•June 2015•August 2015

Common Issues with Budget Projections•Overestimate line items until the end of the program and have a large carryover amounts.•Benefit projections do not include transmittals that are pending approval from utility vendors. •Underestimated eligibility expenses and overdrawn allowable budget percentages.

COMMON BUDGET ISSUES

Contracts Amendments/Budget Modifications•Contracts will be distributed annually•Start all budget modifications at #1 with each year•Budgets have exceeded required percentages•Budget modifications do not match the amounts paid on IHCDA online

Administrative Expenses•Spend more in eligibility expenses than were distributed in benefits•Submit claims when there are no funds available

Energy Education•Overestimate Energy Education and then reducing the line item substantially at the end of the program year

FY2015 EAP FUNDING• Continuing Resolution was approved and IHCDA released $20M on October 1, 2014

• $1M was transferred to Wx

• Funding Scenario• Indiana received $75.8M in FY2014, it is anticipated funding will be level• Indiana allocated $3,203,922.50 for this year’s State EAP program, it is

anticipated funding will be level

• Timeline to Release Funds• Contracts went out on 10/2• Amended as funds are released and available

• Expected Budget Issues• There is a call from the House and Senate to restore LIHEAP to $4.7B for 2015• House and Senate formulas have different formulas• Potential impact if the proposed budgets exceed limits set in the Budget Control Act

FY2015 STATE EAP FUNDINGEstimated Budget: $3.2M-$3.8M

Winter Season Assistance•$60 in Regular Assistance- toward the primary heating source•Up to $150 in Crisis Assistance at the time of initial application•If the benefit is not distributed in the winter due to ineligibility, it may be distributed during the summer months to the primary heating source

Post- Moratorium Assistance•March 16, 2015 to August 15, 2015•Homeowners in crisis (with a disconnect notice) may receive one additional crisis benefit up to $150•Benefit may be distributed to the heating or electric source

Weatherization Deferral Assistance•A portion of the funds will continue to assist with Healthy Homes-related issues in Weatherization. •These funds will target decreasing the weatherization deferral rate.

FY2015 BENEFIT AMOUNT

• Price per point will remain $20

• Decrease the Electric Benefit to $60

• New Regional Differentials • $15-North – decrease of $5.00• $10-Central• $5-South

• New max benefit amount will be $395 (N), $390 (C), $385 (S)

• Anticipating another Propane Shortage

• Summer Cool is not guaranteed*

PREPARING FOR WINTER 2015

• Decreasing the Electric Benefit and North Differential will help us to give our bulk fuel households an additional benefit

• What we know:• Last year we were always about $400 short from mitigating a crisis for our bulk

fuel households• Their average bill was about $1100-$2500• We could only pay for ½ of the bill

• Last season we needed to release an additional $5M, to provide emergency assistance during the propane crisis

• Reduction in the benefit, will prepare us to put $4M toward getting ahead of this issue if gas prices spike again

PREPARING FOR PROPANE GAS CRISIS

Program Year 2014•Indiana instituted the Summer Fill Program and offered delivered fuel customers with $400 crisis benefits.•Indiana released a second summer crisis benefit in August 2014.•Applicants who were subsidized were also eligible to receive crisis assistance

Program year 2015•Indiana will set aside up to $4M of program funds to support delivered fuel customers.•Requirements to Receive Bulk Fuel Crisis:

• Must be approved for LIHEAP benefits• Have a documented energy crisis (out of fuel or nearly out of fuel)• Indiana will allow subsidized households to receive assistance.

POLICY UPDATES

OVERPAYMENT POLICY UPDATE605.2 Overpayments An overpayment occurs when it is found that a client was overpaid. These are funds that need to be returned to the program. The funds are removed from the client’s account and returned to IHCDA from the utility vendor if the error is detected within sixty (60) days of the application’s initial approval or denial. If the overpayment is discovered after the aforementioned sixty (60) day timeline, the LSP will be required to make all repayments to IHCDA. 

OVERPAYMENTS• An overpayment occurs when it is found that a client was overpaid. There are

funds that need to be returned to the program.

• The money is not due to the client, nor does it get added back into the agency’s budget.

• Agencies cannot pay for negative adjustments to client benefits with federal funds (Leveraging, CSBG, or otherwise). Agencies must pay for the overpayments from their corporate unrestricted funds. Overpayments will be applied back to the block grant, not the individual agency’s budget.

• Please note that utility vendors have the option to decline the overpayment request because services and/or discounts have been rendered to clients. If utility vendors opt not to pay for overpayments or put charges back on clients’ accounts, the agencies will be required to remit the funds back to IHCDA from its private, corporate funds. IHCDA will send a remittance for payment to the CAA.

COMMON ISSUES WITH OVERPAYMENTS

• Agency have contacted utility vendors about overpayments, but have not submitted overpayment remittances in RIAA for payment

COMMON ISSUES WITH FISCAL REVIEW• Agencies do not have the signed confirmation sheet from the utility vendors

• The amount of the transmittals submitted for payment does not equal the amount that the utility vendor approved on the signature sheet

• The transmittals took longer than 5 days to be remitted to IHCDA for payment after they were approved by the utility vendor

RECAPTURE AND REDISTRIBUTION

Low Income Home Energy Assistance ProgramLI-14-04: Recapture and Redistribution of FundsEffective Date: February 13, 2014

Policy: To ensure that LIHEAP dollars are maximized for the duration of the program year, local service providers are required to conduct periodic funding analyses and remit the information to the Community Programs Manager for review. The funding analyses are due February 28, April 25, and June 30 of each program year. The local service provider will submit the following report for each funding source to the Community Programs Specialist. The final report is reviewed by the Community Programs Manager and funding recommendations are submitted to the Chief Community Programs Officer for final approval.

RECAPTURE AND REDISTRIBUTIONLine Item Budgeted

AmountExpended

through 5/31/Carryover Amount

Exceeded allowable %

Eligibility        

Program Support

       

Family Development

       

Energy Education

       

Regular        

Crisis Assistance

       

Note: Technology Enhancement will be added for PY2015

RECAPTURE AND REDISTRIBUTION

Good Cause Waiver Submission: Once the February 28 analysis is completed, the Community Programs Manager will develop the Good Cause Waiver and submit to the Chief Community Programs Officer for final review. The final waiver will be distributed to the network by March 15 with a public comment period open for seven days. The network includes: local service providers, utility vendors/associations, and posted on the website under Public Notices.

The public comment must end by March 22. Final revisions are made, if necessary, and remitted to HHS for approval on or after April 1. It is highly recommended that the Good Cause Waiver be submitted to HHS on April 1 for timely approval, as the process may require the submission of additional information and revisions to the waiver request.

RECAPTURE AND REDISTRIBUTION

Funding Reallocation: If the Good Cause waiver is approved, the Community Program will notify the weatherization program of the approval, its effective date, and amount of the additional funds.

RECAPTURE AND REDISTRIBUTION

Summer Cool Program: Historically, the approval is sent around the same time as the submission of the second funding analysis report. The Community Programs Manager will finalize the summer cool benefit amount and administrative budget. The Community Programs Manager will outline the process to recapture and redistribute funds, where applicable.

Contract Amendment: Local service providers will be notified at least fourteen (14) days prior to the recapture and redistribution of funds. Agencies will be required to submit any amendments to the carryover amounts submitted. Amendments for the summer cool program will be submitted by the first day of the summer cool program, with subsequent program guidance.

RECAPTURE AND REDISTRIBUTION

Energy Crisis Intervention: If an energy crisis is identified or energy emergency is declared during the funding analysis calendar, the state office may amend the funding analysis schedule to accommodate the energy needs of low income households. Funding analysis reports would be due by January 31 of the program year.

The Community Programs Manager will determine if a recapture is required to mitigate the crisis. Local service providers will be notified of the recapture and redistribution of funds at least five days prior to the funding realignment.

REQUESTING ADDITIONAL FUNDS

Low Income Home Energy Assistance ProgramLI-14-03: Distribution of Additional LIHEAP AssistanceEffective Date: February 13, 2014

Policy: Agencies may request additional funds from the state if they have obligated at least 85 percent of their current available benefit dollars (regular and crisis assistance). A request for additional funds must be sent to the Community Programs Manager. The request should be sent by the Executive Director.

It is preferred that the request be submitted on agency letter head and must include:•Estimated number of clients to be served and average benefit per client (this should include a summary of appointments currently scheduled and estimated number of mail applications to complete)•Estimated amount of funds to be used toward program administration•Total amount of funds needed•Estimated length of time that the funds will cover

REQUESTING ADDITIONAL FUNDS

The program manager will review the funding request to ensure that the information provided reconciles and evaluates historical trends from the previous year to ensure that the estimated service delivery seems reasonable given trends from the previous years. If there is not enough available funding to complete the request, the Community Programs Manager will request that the agencies amend the request based on the balance of available funds.

REQUESTING ADDITIONAL FUNDS

Contract Amendment: Once the request is approved by the Program Manager, notice is given to the Chief Community Programs Officer and internal IHCDA approval is completed. The Amendment, updated Attachment A, and new budget form are distributed to the agencies within two business days of approval by the Community Programs Specialist. The agency will remit the completed documents back to the Community Programs Specialist. The forms are signed by IHCDA management and updated in the data management system.  Executive Signatures of Approval

CHANGES TO MONITORING

1. For FY2015, IHCDA contractors will reviewing a random sampling of agency claims that include EAP expenses.

a. This process will impact agencies who are not scheduled for a CSBG review in the current program year. Additionally, onsite monitoring notification letters will indicate if your agency is subject to this review during the scheduled monitoring visit.

2. Performance benchmarks will be reviewed as well:a. Obligating forty-five percent (45%) of the Grantee’s LIHEAP funding under this

Agreement by December 31, 2014; b. Obligating sixty percent (60%) of the Grantee’s LIHEAP funding under this

Agreement by February 28, 2015; andc. Obligating seventy-five percent (75%) of the Grantee’s LIHEAP funding under

this Agreement t by April 30, 2015.

EAP CLAIMS PROCESS

Administrative Expenses (Eligibility and Program Support)•Reports from accounting software•Invoices, purchase orders, and receipts as needed

Energy Education•Application Actions Report•Sign in sheets•Invoices, purchase orders, and/or receipts for materials/supplies

Family Development•Timesheets, paystubs, or payroll records denoting staff time spent on family development

COMMON EAP CLAIMS ISSUES

Administrative Expenses•Items listed under “miscellaneous”, “other”, or “professional services” without descriptions or supporting documentation•Credit card charges on accounting reports without sending supporting documentation•Supplies without a description

Energy Education•Send a reconciliation report to claim missing households without sending the corresponding reports or sign-in sheets

Family Development•Payroll records do not clearly identify family development hours

QUESTIONS FOR EAP

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WX UPDATE

OMB Update

Funding

Policy Updates

Performance Measures

New Fiscal Monitors

Q & A

WEATHERIZATION INFORMATION

OMB Guidance• New regulation December 2014• Implementation will be effective when the new Wx grants begin

‐ DOE – April 1, 2015‐ LIHEAP – October 1, 2015

• Leaning more toward performance based evaluation• Time to be reviewing the new guidance

FUNDING UPDATES

• $1,000,000.00 of LIHEAP funding issued to Wx Sub-grantees

• Grant agreements and associated documentation sent to Wx sub-grantees on September 30, 2014

• Due to Continuing Resolution expect approximately same amount as last year in regular LIHEAP Wx allocation

• 2014 LIHEAP closeouts due November 15, 2014• Please process any remaining claims as soon as possible

WX POLICY & PROCEDURES MANUAL

Updated Manual• Newly updated version targeted to be sent the end of

this week• Updates will be in red lettering• Updates will be covered at upcoming Wx Managers

Meetings• New language for Production Benchmarks, Tiered

Funding and Quarterly Review

WEATHERIZATION INFORMATION

Performance Benchmarks• Applies to both DOE and LIHEAP Wx funding• Both DOE and LIHEAP budget forms now have monthly

production breakdowns• The monthly production breakdowns become the performance

benchmarks • Unreasonable breakdowns submitted at the beginning of each

grant might be questioned

WEATHERIZATION INFORMATION

Production Benchmark Review • Production will be reviewed quarterly

‐ Grant specific timeline• Review based upon amount of funds claimed through IHCDA and

completions in Roeing• Low performance could lead to reallocation of funding as outlined

in the Policy & Procedures Manual

WEATHERIZATION INFORMATION

Production Benchmark Review• Outlined in the Policy and Procedures Manual• Different for DOE and LHEAP due to grant start & finish

being six months offset• Sub-grantees expected to perform regular and timely

data entry

TIERED FUNDING ALLOCATIONS

Tiered Funding • Sub-grantees who have failed to meet program

expenditure benchmarks across multiple program years may, at IHCDA’s discretion, be placed on a tiered funding agreement. While on a tiered funding agreement sub-grantees must expend funds according to a structured schedule.

• The performance benchmarks, or expenditure percentages, are based on the sub-grantee’s performance in prior years. Failure to meet expenditure benchmarks will result in a reduction in funding with unspent funds to be redistributed to other eligible sub-grantees.

TIERED FUNDING ALLOCATIONS

Tiered Funding Cont’d• Tiered funding agreements will be included as part of

the sub-grantee grant agreement when applicable. • Sub-grantees placed on a Tiered Allocation should

anticipate an increased level of claim review by IHCDA’s Community Programs staff.

TIERED FUNDING ALLOCATIONS

• Sub-grantees on a Tiered Funding Allocation will not receive their full allocation at the beginning of the grant

• Benchmarks will be established and must be met to obtain additional funding

• Past performance or current concerns can justify or create the need for tiered funding

WX FINANCIAL MONITORING

Thomas & Reed• Contracted through end of May 2015• All 23 Wx sub-grantees to be monitored• Reports reviewed by IHCDA• Sub-grantees expected to be responsive• Will need to meet with both Wx and Financial staff• Anticipated to begin within the next two to three weeks

WX FUNDING MANAGEMENT

Sub-grantees need to understand average cost per home• Wx & Finance must work together• Wx & Finance must meet on a regular basis

‐ Ask yourself this question – do you really know what determines the average cost per home?

‐ Wx Program Managers – do you really know what cost are charged to Wx? Have you seen a breakdown?

‐ When was the last time you saw information related to your average cost per home and how much money has been claimed from your Wx grants?

WX FUNDING MANAGEMENT

Better efforts needed to spend LIHEAP and DOE together• Risk of unutilized funds• DOE currently a little over 10% spent six months into the grant

‐ Too much down time on front end‐ Issue with federal reporting ‐ Possible new regulations if improvement does not take place ‐ Creates monitoring issues for IHCDA

• LIHEAP funds being left on the table

QUESTIONS FOR WX

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