On February 13, 2009 PULP submitted its comments regarding the needs assessment and possible changes in next year's plan. In light of increased unemployment, it is likely that the pool of households eligible for HEAP will grow significantly.
PULP focused its comments in the following areas:
The need for more efficient administration
There have been widespread difficulties this year faced by applicants unable to apply, who did not receive timely decisions on submitted applications as required by federal law, and who lacked recourse through a functioning hotline system to resolve administrative problems
PULP cited the need for expansion of the role of community based outreach services and application expediters, in light of the current application bottlenecks and the expected increase in the number of households applying for aid next year.
PULP also cited the apparent need for more auditing oversight of compliance with LIHEAA requirements intended to promote the right to apply for and receive a prompt decision on eligibility for benefits, and asked for additional OTDA analysis of the eligible population in light of expanded eligbility standards and rising unemployment
Vendor Contract Issues
PULP recommended reform of HEAP vendor agreements negotiated between energy providers and OTDA, including provisions that would
- forbid vendors from refusing to accept Emergency HEAP
- Clearly require payments to be credited to bills for service received in the current winter season and not to arrears that are the subject of DPAs in good standing or in abeyance under SSL 131-s
- Require as a condition of vendor payment that utilities demonstrate efforts to implement low income rates
PULP proposed redesign of benefit levels for households with heat included in rent, and expansion of automatic benefit issuance.