LIHEAP Integration with SBC Programs Dangers with LIHEAP

LIHEAP Integration with SBC Programs: Dangers with LIHEAP Participation as Exclusive Eligibility Criterion Roger D. Colton Fisher, Sheehan & Colton Public Finance and General Economics Belmont, MA 02478 June 2002

Five Points of Integration between SBC and LIHEAP w w w Funding: Direct dollars of benefit Oversight: day-to-day program operation, program monitoring, impact and process evaluation, fiscal auditing. Administration: design and operation. Outreach: provision of info and solicitation of participation. Delivery: interface between customer and program.

Flip Sides of Outreach Integration w Automatic enrollment because of public assistance participation • Lifeline: Ohio, New York • SBC program: Texas, California w Required LIHEAP enrollment • Required assignment to company providing SBC benefit

Legal restrictions Section 2602(f)(1) (LIHEAP statute): . . . the amount of any home energy assistance payments or allowances provided. . . shall not be considered income or resources of such household (or any member thereof) for any purpose under any Federal or State law, including any law relating to taxation, food stamps, public assistance, or welfare programs. (emphasis added).

Disparate impacts w Require condition that disproportionately excludes protected class. • For example: require high school diploma as condition of employment. w Prohibit condition that disproportionately excludes protected class. • For example, bank employment by person who has been subjected to arrest.

Iowa LIHEAP study Statewide, Hispanics represent 2. 4% of LIHEAP participants. w Statewide Hispanics represent 2. 8% of total population. w But, in 12 of 18 Community Action Agency territories, Hispanics are underrepresented. w • In many CAA territories, Hispanics are underrepresented by 30 - 50%.

A Side Observation In addition to SBC participation, LIHEAP participation can be used for other purposes. w In Iowa, winter shutoff moratorium protections are made dependent upon whether someone has applied for LIHEAP. w In Iowa, Hispanics in particular, are disproportionately denied winter shutoff protections. w

For more information roger@fsconline. com