Weatherization Assistance Program: The Federal Perspective (Part 1)

1. Weatherization Assistance Program: The Federal Perspective (Part 1) March 3, 2011 Jean Diggs and Christine Platt Patrick

2. W EATHERIZATION GRANT GUIDANCE The Difference of 10-1 and 11-1 Presenter: Jean Diggs

3. WAP GRANT GUIDANCE 11-1 • NATIONAL EVALUATION: Grantees and subgrantees can track the progress of the national evaluation and see early results through regular postings at: • http://weatherization.ornl.gov/evaluation_nr.shtml. • PROGRAM OVERSIGHT: • - Enhanced monitoring by POs and IG • - Increased oversight surfaced several areas of concern. • - Result is DOE will place special emphasis on several key areas

4. WAP GRANT GUIDANCE 11-1 • CONTINUING RESOLUTION (H.R. 3082): - Until March 4, 2011 - DOE will send out WPN-11-2 Allocations - Grantees and subgrantees will be notified via a specific program notice if final appropriations allow for Sustainable Energy Resource and Consumer Grants in 2011.

5. WAP GRANT GUIDANCE 11-1 • HISTORIC PRESERVATION. • Prototype Programmatic Agreement established. • This streamlined process will continue to be used under the annual program award. • Additional information can be found in Weatherization Program Notice 10-12. • VOLUNTARY NATIONAL STANDARDS FOR WEATHERIZATION • Suite of voluntary national guidelines and a companion set of Knowledge, Skills and Attributes for workforce involved in residential energy efficiency • Strategy to support employment and entrepreneurial opportunities for WAP and other workers for the future

6. WAP GRANT GUIDANCE 11-1 • BEST PRACTICE GUIDES FOR WEATHERIZATION: • Keen interest in best practices for every aspect of the Program • WAP has posted and will continue to post best practices on WAPTAC at www.waptac.org

7. WAP GRANT GUIDANCE 11-1 • TABLE OF CONTENTS 5.13 – Incidental Repairs 5.23 – Eligible Dwelling Units 5.24 – Use of WAP Funds for Add-on/Call-back • 1.3 ADJUSTED AVERAGE: • The adjusted average expenditure limit for Program Year 2011 is $6,572 • The adjusted average for renewable energy measures increased from $3,243 in 2010 to $3,279 for 2011

8. WAP GRANT GUIDANCE 11-1 • 4.0 GRANTEE PROGRAM OVERSIGHT (Program Monitoring) • DOE has increased its monitoring efforts • Project Officers perform weekly, monthly, and quarterly desktop reviews as well as site visits. • Minimum Frequency of On-Site Monitoring visits per Year include (more visits may be required based on specific situations or needs): • Grants over $90 Million (Quarterly) • Grants between $90 Million - $40 Million (Three visits) • Grants under $40 Million (Semi-Annual)

9. WAP GRANT GUIDANCE 11-1 • 4.0 GRANTEE PROGRAM OVERSIGHT (Program Monitoring) (cont’d) • DOE oversight also includes Quality Assurance visits. • The Institute of Building Technology and Safety (IBTS). • IBTS will perform a minimum of 30,000 quality assurance visits. • The Grantee is the responsible entity for DOE grant • DOE recommends that Grantees make at least quarterly visits • Five percent of work at each subgrantee • More frequently if justified

10. WAP GRANT GUIDANCE 11-1 • 5.2 MULTI-FAMILY ELIGIBILITY: Questions on whether a building meets the criteria should be directed to the DOE Project Officer. • DOE issued the following Program Notices on multi-family related issues: • WPN 10-15, Final Rule on Amending Eligibility Provisions to Multi-Family Buildings for the Weatherization Assistance Program; • WPN 10-15A, Guidance Regarding Accrual of Benefits to Low-Income Tenants in Multi-Family Buildings under the Weatherization Assistance Program; • WPN 10-17, Guidance on Using Non-Federal Resources as a Buy-Down for Meeting the Savings-to-Investment Ratio for Materials Used in the Weatherization Assistance Program.

11. WAP GRANT GUIDANCE 11-1 • 5.5 ENERGY AUDIT CRITERIA: WPN 01-4: (cont’d) Note: Many Grantees are currently delinquent in submitting their energy audit procedures for revalidation. • DOE will take more aggressive steps to ensure Grantees meet this requirement • Manufactured Home Audits: Grantees may elect to use alternative energy audits provided they are approved by DOE. • Multi-Family Audits: • Where multi-family dwelling units represent more than 20% of building type, must submit multi-family audit and procedures in accordance with WPN 01-4

12. WAP GRANT GUIDANCE 11-1 • Multi-family audits – cont’d. • Less than 20 and do not have DOE approved audit, the Grantee must take two actions • Describe in State Plan approach • Submit to DOE necessary material to approve the multi-family building PRIOR to beginning work

13. WAP GRANT GUIDANCE 11-1 • Deleted the Energy Crisis which was the old 5.8 • 5.8 DETERMINING ELIGIBILITY LEVELS: • Added the definitions of low-income • 5.9 DEFINING INCOME: • DOE issued WPN 10-18, 2010 Poverty Income Guidelines and Definition of Income issued September 20, 2010. • Revised definition of income. • Also clarified cash receipts, exclusions, proving eligibility, child support, annualizing income, and re-certification. Note: Grantees and subgrantees are reminded that the supporting documentation for applicants applying for weatherization that may be on a waiting list or for other reasons must have their eligibility documentation updated at least annually.

14. WAP GRANT GUIDANCE 11-1 • 5.10 DETERMINING PRIORITY SERVICE: • Lists out five priority groups • Reminded everyone that housing type is not a recognized priority, and • That you cannot discriminate due to the type of home

15. WAP GRANT GUIDANCE 11-1 • 5.12 ENERGY-RELATED HEALTH AND SAFETY: • The primary goal of the WAP is energy efficiency. • Goal endures even with the program changes that allow the DOE funds to be used for health and safety risk mitigation. • DOE encourages Grantees to be prudent in their oversight of the percentage of funds approved for health and safety mitigation on homes weatherized • WPN 11-6 has been issued

16. WAP GRANT GUIDANCE 11-1 • 5.12 ENERGY-RELATED HEALTH AND SAFETY: (cont’d) Note: DOE issued Health and Safety Guidance in Weatherization Program Notice 02-5 on July 12, 2002. DOE issued revised Health and Safety Guidance in Weatherization Program Notice 11-6 in early January 2011. Grantees should use the revised guidance in developing their health and safety plans. • 5.13 INCIDENTAL REPAIRS: • Grantees and subgrantees are reminded that the WAP is not a rehabilitation or general repairs program. • Provides definition of Incidental Repairs in Section 440.3 Definitions • Repair to a roof to protect the insulation installed is allowable • Expanding this definition to include roof replacement or for other non-energy related repairs is not a permissible with DOE funds

17. WAP GRANT GUIDANCE 11-1 • 5.15 ENERGY-RELATED MOLD AND MOISTURE IMPACTS: [Deleted Mold-Related Weatherization Procedures Paragraph] • 5.16 REWEATHERIZATION: September 30, 1994 Note: The term “Reweatherization” applies only to those units which fall into the category of time indicated above and described under 10 CFR 440.18(e)(2)(iii).

18. WAP GRANT GUIDANCE 11-1 • 5.22 HISTORIC PRESERVATION: • Mentioned previously • DOE did receive the ACHP Chairman’s award recognizing both the DOE and National Conference of State Historic Preservation Officers.  • The award was given to recognize everyone’s contributions to creating a workable solution to the number of transactions that needed to be completed in order to allow ARRA money to be sent. • New Program Manager accepted the award for DOE The weatherization of non-stationary campers and trailers that do not have a mailing address associated with the eligible applicants is not allowed. The use of a post office box for non-stationary campers or trailers does not meet this requirement.

19. WAP GRANT GUIDANCE 11-1 • 5.23 ELIGIBLE DWELLING UNITS: • Subgrantees should exercise caution in dealing with non-traditional type dwelling • Shelters • Apartments over businesses, etc. • Consideration on weatherizing these types of units should be coordinated with the Grantee or if necessary approved by the DOE Project Officer prior to weatherization.

20. WAP GRANT GUIDANCE 11-1 • 5.24 USE OF WAP FUNDS FOR ADD-ON/CALL-BACK WORK:  As a general rule, Grantees and subgrantees may not charge the WAP for additional work on homes that have already been reported to DOE as completed, weatherized units.  WPN 11-03 provides specific guidance on this type of activity. Note: Under no circumstances can any of these activities be covered under the reweatherization provisions of 10 CFR 440.18(e)(2)(iii).

21. WAP GRANT GUIDANCE 11-1 • 6.2 REPORTING DOE COMPLETED UNITS: • DOE recommends that final inspections be conducted by a person not associated with actual work

22. Inspector General and General Accountability Office IG/GAO Reports: A Review of Findings and Next Steps Presenter: Christine Platt Patrick, DOE Policy Advisor

23. Overview • Introduction • The IG/GAO • Findings and Trends • Next Steps

24. IG/GAO – The Process • The Inspector General (IG) Mission - To help the Department and the American taxpayer by identifying opportunities for cost savings and operational efficiencies in Department programs; and returning hard dollars to the Department and the U.S. Treasury as a result of Office of Inspector General civil and criminal investigations. • The General Accountability Office (GAO) - GAO exists to support the Congress in meeting its constitutional responsibilities and to help improve the performance and ensure the accountability of the Federal government for the benefit of the American people.

25. IG/GAO – The Process • The audit process commences upon receipt of the incoming notification letter from IG or GAO of their intent to conduct a review with EERE. Information contained in the notification letter includes: • Job title, job code and a brief description of the assignment; • Indication of whether the audit is the result of a Congressional request or a IG/GAO initiative; • Proposed entrance conference dates; • Locations and specific program offices where work will be performed, and • Identification of the performing division, and the name and telephone number of the appropriate IG/GAO contact for the audit.

26. IG/GAO – The Process • Attend entrance conference • Respond to requests for information and documentation • Statement of Facts/Coordination Copy • Draft Report • Respond with management decision letter with corrective actions and estimated completion dates • Exit Conference • Final Report

27. IG/GAO – Findings and Trends • General IG/GAO Findings: • Substandard performance in weatherization workmanship • Substandard performance in initial home assessments • Assessments that called for inappropriate weatherization measures • Assessments overlooked key measures to make homes more energy efficient • Inadequate oversight of contractors • Inaccurate documentation for contractor billing • Homes failing final inspection • Inadequate recordkeeping • Inadequate payroll systems to track employee’s time on projects • Incomplete client files • Fraud, waste and abuse of funds

28. IG/GAO – Next Steps • Investigations Are Changing Focus • Prior Focus: Department level • New Focus: CAA level

29. IG/GAO – Next Steps What CAAs Can Do

30. IG/GAO – Next Steps • Procure contractor weatherization services through a competitive process as required by Federal regulations and perform cost analyses in the selection of contractors to ensure price competiveness. • Obtain and/or review supporting documentation for contractors' invoices to ensure that materials and labor costs incurred on projects are associated with allowable weatherization services and materials. • Ensure that employees charging payroll costs to the Weatherization Program Recovery Act grants are actually providing such services to the Program.

31. IG/GAO – Next Steps • Develop written policies and/or procedures for ensuring cost reasonableness and supportability. • Develop/ensure payroll systems are structured to track employee's time incurred on projects. • Ensure payments for expenditures are appropriately documented and accounted for. • Ensure contractors are billed for labor charges that have been incurred and for materials that have been installed.

32. IG/GAO – Next Steps • Initial assessments that called for inappropriate weatherization measures or the assessments overlooked key measures needed to make the homes more energy efficient. • Ensure that income eligibility source documentation be a part of every client’s file. • Ensure the eligibility documentation, whether stored electronically or hard copy (off site is ok), be readily available at the request of an outside reviewer.

33. Inspector General IG Hotline Complaints

34. Questions?