Arkansas Administrative Code
Agency 016 - DEPARTMENT OF HUMAN SERVICES
Division 20 - Division of County Operations
Rule 016.20.16-004 - FFY 2017 Low Income Home Energy Assistance Program (LIHEAP)

Current through Register Vol. 49, No. 9, September, 2024

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FFY 2016-2017 PLAN ATTACHMENTS

Ms. Lauren Christopher, Director

Division of Energy Assistance

Office of Community Services

U.S. Department of Health and Human Services

370 L'Enfant Promenade, S.W.

Washington, DC 20447

Dear Ms. Christopher:

As Governor of the State of Arkansas, I am delegating authority to the Assistant Director of the DHS Division of County Operations/Office of Community Services to sign the Department of Human Services Low-Income Home Energy Assistance Program (LIHEAP) Assurances for the FY 2017 LIHEAP State Plan.

If you have any questions or concerns, please contact Ms. Lorie Williams, DCO Assistant Director, Arkansas Department of Human Services, at (501) 682-8714. We appreciate your partnership and continued support.

Thank you for your attention to this matter.

FFY 2016-2017

BENEFIT MATRIX WINTER HEATING PROGRAM

NOTE: Any household with five or more members will receive the payment amount in the far right column marked five and above on MCI.

FFY 2016-2017

BENEFIT MATRIX SUMMER COOLING PROGRAM

NOTE: Any household with five or more members will receive the payment amount in the far right column marked five and above on MCI.

CONTACT PERSON: Shirley Mason

NOTICE OF RULEMAKING AND PUBLIC HEARING

The Department of Human Services, Division of County Operations, intends to adopt a State Plan for distribution of Low-Income Home Energy Assistance Program (LIHEAP) Block Grant funds and administration of the Home Energy Assistance Program, for Federal Fiscal Year 2017, covering the period from October 1, 2016 to September 30, 2017. Arkansas administers the LIHEAP Block Grant under Public Law 97-35, as amended. Funding is expected to be approximately $27,000,000.00.

The draft State Plan for LIHEAP is available for review at the Home Energy Assistance Program office on the 3rd floor of Donaghey Plaza South, Seventh and Main Streets, in Little Rock, during business hours, 8:00 a.m. to 4:30 p.m., or copies may be obtained by contacting the Office of Community Services at (501) 682-8715. You may also access it on the DHS website http:humanservices.arkansas.gov/Pages/LegalNotices.aspx. All comments must be submitted in writing to the address indicated above no later than July 30, 2016.

Those who wish to comment on the proposed plan may attend the public hearing closest to you or you may comment in writing to the state agency listed below. All comments must be submitted no later than 30 days from the date of this newspaper notice to:

Division of County Operations

ATTN: Office of Community Services/HEAP Unit

Post Office Box 1437, S330 Little Rock, Arkansas 72203

Arkansas Department of Human Services

Division of County Operations/Office of Community Services

Public Comment Report - Arkansas Low Income Energy Assistance State Ptan (LIHEAP)

Public Hearings

The Low Income Home Energy Assistance Program (LIHEAP) staff and the Assistant Director of the Arkansas Department of Human Services/Division of County Operations/Office of Community Services conducted four public hearings. The public hearings informed the public of the upcoming submission of the LIHEAP State Plan and key facts regarding the administration and operations of the FY 2016-2017 LIHEA Program. Comments and concerns were expressed regarding the activities currently considered as Administrative Costs.

Legal notices were published in the Arkansas Democrat - Gazette for three (3) consecutive days, July 1-3, 2016. The 2016-2017 Low Income Home Energy Assistance Program State Plan was made available for public inspection and comments for 30 days (July 1-30, 2016).

Those who wished to comment could respond orally at the Public Hearing or submit written comments to the DHS/DCO Office of Community Services.

July 11,2016 - Springdaie, Arkansas

The Public Hearing was conducted by Shirley Mason, LIHEAP Program Manager and Lorie Williams, Assistant Director.

Three people attended the Public Hearing. Each person was provided an agenda and a copy of the State Plan Summary. Upon completion of the oral presentation by the representatives from the DHS/OCS, those attending were invited to ask questions and to make comments.

During the Public Hearing, there were no comments regarding the LIHEAP State Plan. However, there were concerns regarding the administration of the LIHEAP Program funds.

Questions were asked by Blain Lawrence, LIHEAP Coordinator OOI, Audra Butler, COO, ARVAC, and Casey Beavers, LIHEAP Coordinator EOAWC.

Question #1: Audra Butler

Can A-16 funds be transferred into the Crisis Program if agencies opt-out of the A-16 program? Response; Yes.

Question #2: Blain Lawrence

Can LIHEAP Program Funds be used to pay direct program expense such as salaries for case managers, program supplies, etc.?

Response by State Agency Lorie Williams and Shirley Mason

It was explained to the attendees that the allocation for the administration of the LIHEAP program is a maximum of 10% per Federal regulations and that percentage cannot be increased.

The State Agency, however, will review the activities currently being considered as Administrative cost and determine if changes can be made.

July 12,2016 - BatesviHe, Arkansas

The Public Hearing was conducted by Shirley Mason, LIHEAP Program Manager and Lorie Williams, Assistant Director.

Six people attended the Public Hearing. Two out of the six were private CPAs. The remaining four were from the Community Action Agencies. Each person was provided an agenda and a copy of the State Plan Summary. Upon completion of the oral presentation by the representatives from the DHS/OCS, those attending were invited to ask questions and to make comments.

During the Public Hearing, there were no comments regarding the LIHEAP State Plan. However, there were concerns regarding the administration of the LIHEAP Program funds.

Questions were asked by Kathy Ruminer, LIHEAP Coordinator, NADC, Staci Albert, NADC, Charlie Morris, Director, NADC, Ron Cantrell, Marie Thorn, NADC, and John Welch,

Question #1: Staci Albert

Can you take $300 + $500 to pay the Crisis bill?

Response by State Agency Shirley Mason

Benefits from Regular Assistance and Crisis Intervention may be coordinated.

Question #2 Kathy Ruminer

What determines life-threatening for Crisis?

Response by State Agency Shirley Mason

A life threatening event would be one that could prove fatal for a household in the event there was a loss of energy. This type of determination is often accompanied by a written statement from a certified medical professional.

Question #3 Ron Cantrell

Is the LIHEAP Allocation a 2-tier test based on the previous funding and the number of low-income person?

jesponse by State Agency Shirley Mason

The LIHEAP allocation is based on the US Census Data and Poverty Rates for each county. We are currently reviewing that information to update from the latest US Census Data.

Question 4 John Welch

Is funding stagnated for ten years?

Response by State Agency Shirley Mason

The LIHEAP funding allocation Distribution formula has not been changed in several years. We are currently reviewing that information to update from the latest US Census Data.

Question #5 Charlie Morris Is the entire funding for weatherization funded through one entity? (Department of Energy) Is the entire funding for weatherization funded through one entity? (Department of Energy) weatherization?

Response by State Agency Shirley Mason

The Arkansas Department of Energy is the Sub-grantee for LIHEAP Weatherization funds. For information on becoming a sub-contractor for LIHEAP WAP, you may contact the Weatherization Section at the Arkansas Department of Energy.

Question #6: Charlie Morris Can LIHEAP Program Funds be used to pay direct program expense such as salaries for case managers, program supplies, etc.?

Response by State Agency Lorie Williams and Shirley Mason

It was explained to the attendees the allocation for the administration of the LIHEAP program is a maximum of 10% per Federal regulations and cannot be increased.

The State Agency, however, will review the activities currently being considered as Administrative cost and determine if changes can be made.

July 13,2016 - Prescott, Arkansas

The Public Hearing was conducted by Shirley Mason, LIHEAP Program Manager and Lorie Williams, Assistant Director.

Two people attended the Public Hearing. Each person was provided an agenda and a copy of the State Plan Summary. Upon completion of the oral presentation by the representatives from the PHS/OCS, those attending were invited to ask questions and to make comments.

During the Public Hearing, there were no comments regarding the LIHEAP State Plan. However, there were concerns regarding the administration of the LIHEAP Program funds.

Questions were asked by Todd Anderson, LIHEAP Program Director, CADC, and Jim McPhaul, Executive Director, SWADC.

Question #1: Todd Anderson

Can LIHEAP Program Funds be used to pay direct program expense such as salaries for case managers,

program supplies, etc.?

Response: The State Agency, however, will review the activities currently being considered as Administrative cost and determine if changes can be made.

Question #2: Jim McPhaul

Any Idea regarding the time frame that we receive notification regarding admin program cost?

Response: OCS will have to make an assessment and present it to the Division Director for review.

Juiy 14,2016 - Warren, Arkansas

The Public Hearing was conducted by Shirley Mason, LIHEAP Program Manager and Lorie Williams, Assistant Director.

Five people attended the Public Hearing. Each person was provided an agenda and a copy of the State Plan Summary. Upon completion of the oral presentation by the representatives from the DHS/OCS, those attending were invited to ask questions and to make comments.

During the Public Hearing, there were no comments regarding the LIHEAP State Plan. However, there were concerns regarding the administration of the LIHEAP Program funds.

Questions were asked by Alethea Dallas, Interim Director, SEACAC. Questions #1 and #2: Alethea Dallas, Interim Executive Director, SEACAC

Define Administration and Program Cost?

Response: Because the LIHEAP Program is a block grant, there are certain activities that can be allowed either under Administrative or as Program. We understand that the Community Action Agencies would like for the State to review the current activities and determine if some can now be considered as

Program Costs. The State Agency will review the activities currently being considered as Administrative cost and determine if changes can be made.

Is there any flexibility with Administration Cost vs Program Cost?

Response: The State Agency will review the activities currently being considered as Administrative cost and determine if changes can be made.

Written Comments

The agency received seven written comments. All but one was related to the activities allowed in Administrative and Program Costs. The other was concerning the allocation for each agency and how that is determined. (See Attachment I).

A written response to those comments was issued by the DHS/Office of Community Services (See Attachment II).

NPO BUILDERS, LLC

185 MILL RUN TRL

BATESVILLE, AR 72501

(870) 307-5264

July 13, 2016

Division of County Operations HEAP Unit

P.O. Box 1437, Slot S-330 Little Rock, AR 72203

RE: HEAP Public Hearing Comments

To Whom It May Concern:

I appreciate Ms. Williams and Ms. Mason for visiting Batesville and presenting the HEAP program information and listening to various comments and suggestions from local residents. In accordance with the request for comments, I'd like to offer the following.

I'm a CPA as well as a Certified Financial Planner, and a Certified Fraud Examiner. My experience since 1980 has been almost exclusively intertwined with both nonprofits that receive governmental grant funding, and governmental organizations or sub-units. This experience includes audit, consulting, or volunteer work with at least 5 of the State's Community Action organizations. I've also served as a CFO/Treasurer for one of Arkansas' larger retailers and a couple of govemmentally-funded nonprofits.

My experiences at these, and other nonprofits, has shown that there are apparently some serious challenges for the CAPs fiscally to remain solvent, viable, and robust. Some have seen their financial positions deteriorate dramatically over the past decade, almost to the point of closing their doors. More certainly some have had to curtail various programs and services, cut staff, and as a result shrink their ability to consider further growth and service opportunities.

I only mention this because with relative ease, the DCO, specifically HEAP policy, can make a profound and positive impact moving forward for these community service providing agencies.

Comment #1

At this time HEAP direct line client service staff and their related costs are considered to be "administrative" and are subject to a very limited funding allocation within each CAP'S HEAP budget.

While not subject to the OMB Omnicircular*s 10% de minimus overhead rate, that rate might be considered to establish what federal officials considered a bare but reasonable level for administrative costs. Some grants allow the 10% (or more) overhead to flow down to the subrecipiertt level but such is not the case with HEAP subrecipients. Since the total administrative costs for ALL levels of program services is 10%, the subrecipients, after the State takes its needed administrative portion, are left with an extraordinarily low level of funding to cover both its {1) indirect administrative costs and (2) the costs for direct service staff, which includes Case Management and Outreach.

To illustrate, for one of the Agencies I serve, the average "Indirect" or pure administrative allocation allowed was only 2.49% for FY 2014, and 1.16% for FY 2015! The rest of their small administrative share was made up of direct line service staff and related costs. Since Indirect'* costs have to be allocated proportionately, you can see the situation is quite challenging.

"Helping Nonprofits Manage Their Finances, Master Their Minims*

According to IM 2000-12, as well as a LiHeap Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State to consider outreach and case management activities as administrative. The Issue Brief indicates that Illinois, Indiana, and Washington consider outreach, case management, budget counseling, energy education, vendor negotiations to be program, not administrative costs. IM 2000-12 reminds the States that they have a great deal of flexibility, within TANF general guidelines, to structure programs as they feel work best for themselves.

In order for the CAPs to improve their viability and strength, I recommend the State redefine its administrative component to specifically exclude case management and outreach activities performed for the HEAP program. I am not asking for an increase of the 10% admin cost ceiling from either the State or Federal government. I am asking only that a small portion of the utility assistance funds be redirected to another allowable program cost component - Case Management and/or Outreach (or similar).

Attached are both documents for your review.

I hope you will give very serious and thoughtful consideration to this change. Alhough small for the HEAP program as a whole, such a change would be extremely meaningful to each individual Community Action Agency. It would not be a windfall by any means, but a meaningful tweak to their fiscal health and structure.

Comment #2

Regarding the way that HEAP funds are distributed to the State's subrecipient Community Action Agencies, I hope that the awards are based on current population statistics for low-income persons, rather than statistics that are up to a decade old. There are resources available for reliable estimates annually from the most recent US census, UALR, etc., and perhaps those could be used to ascertain the poverty rates used to determine the allocations of HEAP funds to each CAP. As populations shift, it is possible that continued high funding could be made for areas where poverty is in decline relative to other areas where poverty is growing. Naturally, areas where poverty is growing, is where HEAP funds should be increased. Leaving high funding in areas where poverty rates are decreasing relative to others is, at least anecdotally, harmful to the areas where people in poverty numbers are growing and they should not be penalized with lower than average funding availability.

Again, I hope you might take a close look at the allocation issue as well in order to be sure that it meets the needs of the communities on a current basis.

July 19, 2016

Division of County Operations HEAP Unit

P.O. Box 1437, Slot S-330 Little Rock, AR 72203

RE: HEAP Public Hearing Comments

To Whom It May Concern:

I would like to follow up to my earlier letter responding to your request for public comments regarding the HEAP program as follows:

Transparency

Regarding how the LiHeap funds are distributed state-wide to each community action organization, I believe it is important to have transparency in the distribution model.

Since the methodology, math, source data, etc. are all available under the Freedom of Information Act, it would seem to be extremely helpful if the State would simply provide the allocation details when the award amounts are distributed each year to the CAP agencies.

The population statistics for persons in poverty can be made available by county and show the specific way these statistics are used to determine what share of the State's total funding is made available to each Agency, as well as the State's share of the 10% administrative portion coming out of the CAP Agency totals.

I am led to believe there has been frustration in various efforts to discover this information in the recent past.

Ron Cantrell NPO Builders, LLC 185 Mill Run TRL Batesville, Arkansas 72501

Dear Mr. Cantrell:

Thank you for your comments regarding the LIHEAP State Plan. In response to your question regarding the activities currently being allowed in Administration and Program, the agency will review the activities and determine if any changes can be made. Upon completion of the review the assessment will be provided to the Division Director for review. In addition, the State will discuss with the Community Action Agencies the process of how the allotments are determined.

If you have any questions, please contact Shirley Mason, HEAP Manager at (501) 682-8726.

Division of County Operations HEAP Unit

P.O. Box 1437, Slot S-330 Little Rock, AR 72203

RE: HEAP Public Hearing Comments

To Whom It May Concern:

I attended a recent public hearing about the HEAP program in our area and I'd like to offer the following in response.

As a CPA in the business of helping nonprofits be successful, and particularly with my experience working with Community Action Agencies all over the State of Arkansas, I am concerned about their general financial health and well-being. It seems that many of them are struggling, facing very tough times, and having to make decision about cutting programs and services in the areas they serve.

After attending the public hearing in Batesville, I am led to believe that there is something very important that the State leadership could actually accomplish with very little relative effort, and make a really tremendous impact on these organizations that serve the mission of Congress and the State.

At this time HEAP direct line client service staff and their related costs are considered to be "administrative". Since the total administrative costs for ALL levels of program services is 10% including the State's share, the sub-recipients i.e. the CAP Agencies are left with very little funding to cover both its indirect administrative costs and the costs for direct service staff, who's functionality includes both outreach and case management services. Those two services, according to IM 200-12 do not need to be counted towards the administrative component.

According to IM 2000-12, as well as a LiHeap Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State to consider outreach and case management activities as administrative. The Issue Brief indicates that several other states consider outreach, case management, and other areas of service to be program costs. IM 2000-12 reminds the States that they have a great deal of flexibility in the design of their HEAP program.

I sincerely hope the State will redefine "administration" to exclude case management and outreach activities performed for the HEAP program. The mechanics of such a change would be to move a small portion of the utility assistance funds (2.75%, for example) be redirected to another allowable program cost component which would be something like Case Management and/or Outreach whatever name the State prefers. This level of increase would bring the total for non-utility assistance expenses, excluding Assurance 16 to about 10%, which seems to me to be a great value for the State of Arkansas.

I hope you will give the suggestion very serious and thoughtful consideration. It could make the world of difference to the Agencies entrusted to perform the services OCS asks them to.

John Ed Welch

Welch, Couch & Company, PA

P.O. Box 2094

Batesville, Arkansas 72503

Dear Mr. Welch:

Thank you for your comments regarding the LIHEAP State Plan. In response to your question regarding the activities currently being allowed in Administration and Program, the agency will review the activities and determine if any changes can be made. Upon completion of the review the assessment will be provided to the Division Director for review.

If you have any questions, please contact Shirley Mason, HEAP Manager at (501) 682-8726.

July 14, 2016

HEAP Unit

P.O. Box 1437, Slot S-330

Little Rock, Ar. 72203

RE: HEAP Public Hearing Comments

To Whom It May Concern:

I attended a recent public hearing about the HEAP program in our area and I'd like to offer the following response.

As a resident concerned about the health of the Community Action Agency in our area, I am concerned about their general financial health and well-being.

After attending the public hearing locally, I am led to believe that there is something very important that the state leadership could actually accomplish with very little relative effort, and make a really tremendous impact on these organizations that serve the mission of Congress and the State.

At this time HEAP direct line client service staff and their related costs are considered to be "administrative". Since the total administrative costs for ALL levels of program services is 10% including the State's share, the subrecipients i.e. the CAP Agencies are left with very little funding to cover both its indirect administrative costs and the costs for direct service staff, who's functionality includes both outreach and case management services. Those two services, according to IM 200-12 do not need to be counted towards the administrative component.

According to IM 2000-12, as well as a LiHeap Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State to consider outreach and case management activities as administrative. The Issue Brief indicates that several other states consider outreach, case management, and other areas of service to be program costs. IM 2000-12 reminds the States that they have a great deal of flexibility in the design of their HEAP program.

I sincerely hope the State will reconsider its definition of "administration" to exclude case management and outreach activities performed for the HEAP program.

I hope you will give the suggestion very serious and thoughtful consideration. It could make the world of difference to the Agencies entrusted to perform the services OCS asks them to do.

Augusts, 2016

Mollie Everett

Crowley's Ridge Development Council, Inc.

2401 Fox Meadow Lane

Jonesboro, Arkansas 72403

Dear Ms. Everett:

Thank you for your comments regarding the LIHEAP State Plan. In response to your question regarding the activities currently being allowed in Administration and Program, the agency will review the activities and determine if any changes can be made. Upon completion of the review the assessment will be provided to the Division Director for review.

If you have any questions, please contact Shirley Mason, HEAP Manager at (501) 682-8726.

July 18, 2016

Ms. Lorie Williams, Assistant Director

Division of County Operations

HEAP Unit

PO Box 1437, Slot S-330

Little Rock, AR 72203

RE: HEAP Public Hearing Comments

Dear Lorie:

I heard about the recent public hearing about the HEAP program in Batesville and I'd like to offer the following response.

As the Executive Director of a Community Action Agency in our area, I am concerned about the general financial health and well-being and sustainability of these agencies.

After hearing testimony at the public housing, I am led to believe that there is something very important that the state leadership could accomplish with very little effort, and make a real impact on these organizations that serve the mission of Congress and the State.

At this time HEAP direct line client service staff and their related cost are considered to be "administrative". Since the total administrative cost for ALL levels of program services is 10% including the State's share, the subrecipients i.e. the CAP Agencies are left with very little funding to cover both its indirect administrative costs and the cost for direct service staff, who's functionality includes both outreach and case management services. Those two services, according to IM 200-12 do not need to be counted towards administrative component.

According to IM 200-12, as well as a LiHeap Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State to consider outreach and case management activities as administrative. The Issue Brief indicates that several other states consider outreach, case management, and other areas of service to be program costs. IM 200-12 reminds the States that they have a great deal of flexibility in the design of their HEAP program.

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August 5, 2016

Tim Wooldridge

Crowley's Ridge Development Council, Inc.

2401 Fox Meadow Lane

Jonesboro, Arkansas 72403

Dear Mr. Wooldridge:

Thank you for your comments regarding the LIHEAP State Plan. In response to your question regarding the activities currently being allowed in Administration and Program, the agency will review the activities and determine if any changes can be made. Upon completion of the review the assessment will be provided to the Division Director for review.

If you have any questions, please contact Shirley Mason, HEAP Manager at (501) 682-8726.

July 18, 2016

Division of County Operations HEAP Unit

P.O. Box 1437, Slot S-330 Little Rock, AR 72203

RE: HEAP Public Hearing Comments

To Whom It May Concern:

I attended the recent public hearing about the HEAP program in Batesville and I'd like to offer the following in response.

As Executive Director of Northcentral Arkansas Development Council (NADC), managing a community action agency is very difficult with very limited revenue streams. I am concerned about our general financial health and well-being as I know many of my fellow executive directors with their agencies are as well. We all have our struggles, facing very tough times, and having to make decision about cutting programs and services in the areas we serve.

After attending the public hearing in Batesville, I am led to believe that there is something very important that the State leadership could actually accomplish with very little relative effort, and make a really tremendous impact on our organizations that serve the mission of Congress and the State.

At this time HEAP direct line client service staff and their related costs are considered to be "administrative". Since the total administrative costs for ALL levels of program services is 10% including the State's share, the subrecipients i.e. the CAP agencies are left with very little funding to cover both its indirect administrative costs and the costs for direct service staff, who's functionality includes both outreach and case management services. Those two services, according to IM 200-12 do not need to be counted towards the administrative component. To simplify the situation, one of my fellow directors said "it likes you have $100, out of that $100, $90 goes to the client, and the other $10 goes toward the outreach worker time and effort, paperwork, overhead, accounting, HR, etc. It is too tight of a margin."

According to IM 2000-12, as well as a LiHeap Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State to consider outreach and case management activities as administrative. The Issue Brief indicates that several other states consider outreach, case management, and other areas of service to be program costs. IM 2000-12 reminds the States that they have a great deal of flexibility in the design of their HEAP program.

I sincerely hope the State will redefine "administration" to exclude case management and outreach activities performed for the HEAP program. The mechanics of such a change would be to move a small portion of the utility assistance funds (2.75%, for example) be redirected to another allowable program cost component which would be something like Case Management and/or Outreach whatever name the State prefers. This level of increase would bring the total for non-utility assistance expenses, excluding Assurance 16 to about 10%, which seems to me to be a great value for the State of Arkansas.

We did a calculation on how much more we could receive with the proposed change and it was in the mid $20,000 range. It is not a lot of money but it gives us a little more breathing room to operate our services. I am certain that other agencies with similar and higher allocations would appreciate that extra income as well.

And while on allocations, I would like to make another request on sharing your distribution model with each agency for transparency purposes so each agency has a clearer picture how our funds are determined and funded.

I hope you will give our suggestions very serious and thoughtful consideration. It could make the world of difference to us in performing the services OCS asks of us.

August 5, 2016

Charlie Morris

Northcentral Arkansas Development Council, Inc.

P.O. Box 3349

Batesville, Arkansas 72503

Dear Mr. Morris:

Thank you for your comments regarding the LIHEAP State Plan. In response to your question regarding the activities currently being allowed in Administration and Program, the agency will review the activities and determine if any changes can be made. Upon completion of the review the assessment will be provided to the Division Director for review.

If you have any questions, please contact Shirley Mason, HEAP Manager at (501) 682-8726.

July 20, 2016

Division of County Operations HEAP Unit

P.O. Box 1437, Slot S-330 Little Rock, AR 72203

To Whom It May Concern:

I recently attended a public hearing about the HEAP program for this region of the State of Arkansas and I became concerned about the general financial health of the Community Action Agency in general. 1 encourage the State leadership to take steps necessary to positively impact the Community Action Agency that serve the mission of Congress in the State of Arkansas.

At this time HEAP direct line client service staff and their related costs are considered to be "administrative". Since the total administrative costs for ALL levels of program services is 10% including the State's share, the sub recipients i.e. the CAP Agencies are left with very little funding to cover both its indirect administrative costs and the costs for direct service staff, who's functionality includes both outreach and case management services. Those two services, according to IM 200-12 do not need to be counted towards the administrative component.

According to IM 2000-12, as well as a LiHeap Clearinghouse Issue Brief dated June, 2014, it is not necessary for the State to consider outreach and case management activities as administrative. The Issue Brief indicates that several other states consider outreach, case management, and other areas of service to be program costs. IM 2000-12 reminds the States that they have a great deal of flexibility in the design of their HEAP program.

I sincerely hope the State will reconsider its definition of "administration" to exclude case management and outreach activities performed for the HEAP program.

August 5, 2016

Rick Reed Rick Reed Company P.O. Box 2705 Batesville, Arkansas 72501

Dear Mr. Reed:

Thank you for your comments regarding the LIHEAP State Plan. In response to your question regarding the activities currently being allowed in Administration and Program, the agency will review the activities and determine if any changes can be made. Upon completion of the review the assessment will be provided to the Division Director for review.

If you have any questions, please contact Shirley Mason, HEAP Manager at (501) 682-8726.