Annual and Master File Overview February 25, 2013 10:45 11:40 a.m. Holly Ravesloot Program Specialist, WIPO, U.S. DOE Erica Burrin Team Lead Field Operations, WIPO, U.S. DOE Cynthia Simonson SMS 1 Energy Efficiency and Renewable Energy eere.energy.gov
WPN 13-1 Section 2.0 Grant Application. New 3-Year Grants for 2013. Intergovernmental Review. Application Package. Application Format and Changes. Reporting Requirements. Prior Year Guidance Retractions. 2
3 Year Grants All 2013 grant awards will be issued as new 3-year awards. Impact: Existing DOE awards may need to be extended if funds are still available (contact PO). It s possible to have 2 regular DOE awards and the DOE ARRA award all active with reporting requirements on 3 awards. 3
Application Format and Changes Now required to submit both annual and on-file (master file) annual. Budget Section Expanded. Consolidated repetitive sections between the annual and on-file to minimize duplication. Use the application package (attached to 13-1) while filling out the state plan details. 4
Prior Year Retractions In WPN 12-1 DOE Stated: Grantees that weatherize multi-family units must have a multifamily energy audit and procedures as part of their Program year 2013 plan submittal to DOE. The use of the multi-family energy audit too must include a training component. For Program Year 2013 DOE is retracting this requirement for all Grantees. If 20% of annual production is multi-family then the requirement stands. If not each multi-family building must be submitted to the PO for approval. Grantees are still required to explain how they will address multi-family building in the plan. 5
Application Package Overview. Standard Form 424. Budget. Annual File. Master File. Federal Financial Regulations. 6
Annual File IV ANNUAL FILE IV.1 Subgrantees. IV.2 Production Schedule. IV.3 Energy Savings. IV.4 DOE-Funded Leveraging Activities. IV.5 Policy Advisory Council. IV.6 Hearings and Transcripts. IV.7 Miscellaneous. 7
Master File V MASTER FILE V.1 Eligibility. V.2 Selection of Areas to be Served. V.3 Priorities. V.4 Climatic Conditions. V.5 Type of Weatherization Work to be Done. V.6 Weatherization Analysis of Effectiveness. V.7 Health & Safety. V.8 Program Management. V.9 Energy Crisis & Disaster Plan. 8
The Network Erica Burrin Team Lead Field Operations 9
The Network Subgrantees (IV.1)- Annual File. 440.15; Lists a number of assurances that Grantees must provide in the State Plan. Selection of Areas to be Served (V.2)-Master File. 440.14 (c)(6)(ii); Explanation of method used to select an area to be served by a Weatherization Project. Weatherization Analysis of Effectiveness (V.6)-Master File. 440.14 (c)(6)(i); Analysis may be annually or include a special analysis. 10
Subgrantees Regulations require the Grantee to ensure: Subgrantee is CAA, local unit of government, or other non-profit. Subgrantee is selected on the basis of public comment. Experienced in weatherization/housing renovation. Experienced in serving low-income families. Able to undertake activities in timely manner. Preference to CAAs or other Non-Profits currently administering the Program provided they have done well in the Program. 11
Selection of Areas to be Served WAP Source of Pride: We serve every county in every state (and territory). Grantees should explain: Methodology used to select each area to be served. If using the existing network of agencies, explain why. If using different network of agencies, explain why. 12
WAP Analysis of Effectiveness Each year, Grantees are required to analyze the effectiveness of the Program. Examples of Analyses DOE would be interested in: How the effectiveness of Subgrantee weatherization is assessed? How productivity and energy savings between Subgrantees are compared? How the comparisons are used in the development of T&TA activities and priorities? How is the training capability being assessed and how is the Grantee incorporating monitoring feedback? What is the Grantee doing to be on a path of continuous improvement? How is the Grantee tracking Subgrantee performance reviews? If a Subgrantee has failed final inspections, how are things improving? If a Subgrantee has management findings or concerns cited as a result of Grantee monitoring or audit proceedings, how are things improving? What are the management mechanisms being put in place this year to affect improvement? Are there technical and financial systems that have been reviewed? What has the Grantee done in the area of market analysis to ensure particular measures are being costed accurately? 13
Analysis of Effectiveness DOE has no expectation Grantees undertake ALL analyses written as examples. Purpose is to ensure Grantee is actively improving the program and outcomes as outlined in the Statute. DOE may ask the Grantee about why they have certain Subgrantees in the Program. Possible triggers DOE may want to review during monitoring: Consistent findings that have not been resolved by the Subgrantee. Production numbers by Subgrantee. Material costs for certain measures. 14
The File Cynthia Simonson - SMS 15
Learning Objectives After this session, participants will be able to: Consider alternatives to current practices for maintaining client files. Access materials outlining client eligibility, including how income is defined and verified. Describe building eligibility requirements and instances when a building may not be a good candidate (or ineligible) for services. State DOE s priorities for service. 16
The File There is no DOE requirement for a client file. There is a list of what DOE looks for during Federal Monitoring. There are MANY items DOE expects the Grantee to have available (via the Subgrantee). An easy way is for Grantee to require certain items in a client file. An even easier way is for Grantees to require certain items in a certain order in the client file. Client Info Application Eligibility Qualified Alien Priority Sign offs Unit Info Audit Waivers Work Order Invoice Pictures 17
Eligibility Every dwelling weatherized under the Weatherization Assistance Program must meet both the client eligibility and the building eligibility requirements. 18
Eligibility Documentation Requirements Eligibility levels and documentation procedures must be established by the Grantee. 440.16(a) The Grantee must document how they will ensure no dwelling is weatherized that does not have proper documentation. In the Master File of the Grantee s State Plan. 19
Client Eligibility Income Thresholds Income eligibility must be in accordance with DOE regulations. The family must be: At or below 200% of the poverty level, relevant to size of the family. Eligible for cash assistance payments under Title IV or Title XVI of the Social Security Act. If the Grantee elects, eligible for LIHEAP, provided LIHEAP eligibility is at or below 200% of poverty. 20
Client Eligibility 2012 Poverty Income Guidelines (WPN 12-2) Contiguous States U.S. Grantees Size of Family Unit Threshold 200% 1 $11,170 $22,340 2 $15,130 $30,260 3 $19,090 $38,180 4 $23,050 $46,100 5 $27,010 $54,020 6 $30,970 $61,940 7 $34,930 $69,860 8 $38,890 $77,780 For families with more than 8 persons, add $3,960 for each additional person. * Additional charts available specific to Hawaii and Alaska Effective January 26, 2012 21
Client Eligibility Income Determination (WPN 12-8) Income means Cash Receipts earned and/or received by the applicant before taxes during the applicable tax year(s). 22
Client Eligibility Income Exclusions (WPN 12-8) The following cash receipts are not considered sources of income when determining applicant eligibility. 23
Client Eligibility Qualified Aliens In this, DOE follows HHS. The HHS website has explicit information related to any restrictions on immigrant eligibility. http://aspe.hhs.gov/hsp/immigration/restrictions-sum.shtml 24
Determining Building Eligibility When determining eligibility, Grantees should consider the following: Is this a reweatherization unit? Is this an eligible structure? Is this a rental unit? Is there any other apparent reason to defer? There are many factors to consider when determining eligibility. 25
Building Eligibility - Reweatherization The Recovery Act amended the reweatherization date and now allows Grantees to weatherize homes previously weatherized from September 30, 1994 and earlier. Photo courtesy of Georgia Environmental Finance Authority Photo courtesy of the Tennessee Housing Finance Authority Many homes weatherized before 1994 can benefit from reweatherization so they can save even more energy and money for the clients. 26
Building Eligibility Housing Types There are many housing types that are eligible for the Weatherization Assistance Program - owner and renter-occupied single-family homes, manufactured housing units, and multifamily buildings. 27
Building Eligibility Rental Units Grantees are required to develop a procedure on how their program will ensure the benefits of weatherization to the occupants of the rental units are protected. The rental unit procedures shall ensure: Written permission of the building owner or their agent before commencing work. Benefits of the services accrue primarily to the low-income tenants residing in such units. For a reasonable period of time after completion, the household will not be subjected to rent increases. There are adequate procedures whereby the Grantee can receive tenant complaints and owners can appeal, should rental increases occur. No undue or excessive enhancement shall occur to the value of the dwelling unit. To secure the federal investment and to address issues of eviction from and sale of property, per 10 CFR 440.22(c), Grantees may seek landlord agreement to placement of a lien (or other contractual restrictions) upon the property being weatherized. 28
Building Eligibility Multifamily Eligibility In addition to the rental unit procedures, multifamily buildings may also include the requirements to: Have the financial participation, when feasible, from the building owner(s). A multifamily building may not be weatherized unless: The Subgrantee has obtained the written permission of the owner or their agent. 66% or more of the dwelling units in the building (or 50% for duplexes, 4-unit buildings, and certain eligible types of large multifamily buildings) are eligible. The 66% rule is often referred to as the two-thirds rule. 29
Building Eligibility - Deferrals Grantees must have a clear and concise deferral policy so its Subgrantees know when a building should be deferred. Photo courtesy of Georgia Environmental Finance Authority Homes that have structural issues should be deferred for weatherization assistance. Photo courtesy of UglyHousephotos.com Clutter that limits access to the building or that pose serious health and safety issues that can result in deferral. 30
Checklist Client Eligible Building Eligible Then what? Where do they fall in priority? 31
Determining Priorities for Service Grantees and Subgrantees may target their services to maximize program effectiveness. Per DOE regulations, Grantees must have a procedure to ensure that the following clients have priority: The elderly. Persons with disabilities. Families with children. High residential energy users. Households with a high energy burden. There are a number of population types, such as households with a high energy use, that should receive priority for weatherization services. 32
Summary Grantees are required to provide a description within their State Plan of what documentation is needed to demonstrate a specific unit and client are eligible. Gathering the required documentation is critical to identifying eligible clients. Buildings also must be reviewed (housing type, reweatherization, etc.) to determine whether or not they are eligible for weatherization. Grantees must have a clear procedure for their Subgrantees to prioritize its clients. 33