LIHEAP Integration with SBC Programs: Dangers with LIHEAP Participation as Exclusive Eligibility Criterion

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LIHEAP Integration with SBC ProgramsDangers
with LIHEAP Participation as Exclusive
Eligibility Criterion

• Roger D. Colton
• Fisher, Sheehan Colton
• Public Finance and General Economics
• Belmont, MA 02478
• June 2002

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Five Points of Integration between SBC and LIHEAP

• 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.

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Flip Sides of Outreach Integration

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

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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).

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Disparate impacts

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

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Iowa LIHEAP study

• Statewide, Hispanics represent 2.4 of LIHEAP
  participants.
• Statewide Hispanics represent 2.8 of total
  population.
• But, in 12 of 18 Community Action Agency
  territories, Hispanics are underrepresented.
• In many CAA territories, Hispanics are
  underrepresented by 30 - 50.

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A Side Observation

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

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For more information

• roger_at_fsconline.com