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Once the household has submitted an application and has been deemed or is being deemed eligible for the EAP benefit, the client is protected under the moratorium, whether a benefit has been received or not. If an applicant household is determined to be ineligible for the program, this protection will end immediately. Ineligibility must be communicated to the vendor by the LSP and noted in the statewide database. The LSP is never required to make a pledge to the utility for the moratorium protections to begin. Disconnection Prior to December 1 If a client who has qualified for EAP has a past due bill and that client does not make a payment before December 1, the utility has the right to disconnect that client before December 1, since that client is not yet protected by the moratorium. If the same client has active service as of December 1, the utility may not disconnect that client until March 15. Benefit Refusal A utility vendor may refuse an EAP benefit at any time during the heating season. Benefit refusal does not prevent moratorium protection. A client who has submitted a complete application and is being deemed or has been deemed EAP eligible and has active service on December 1 will receive moratorium protection through March 15. Landlord/Tenant Agreements and Moratorium Protection Circumstances may arise where landlords and tenants must create a utility payment arrangement to ensure that the utility bills are paid on time. This policy provides clarification on moratorium protection when the payment arrangement between the landlord and client is breached. If the utility is listed in the landlord’s name, but the client has breached payment agreement with the landlord, the landlord may request service disconnection during the moratorium period. Though the client was deemed eligible for EAP assistance, the landlord is the customer of record on the utility bill. If the utility is listed in the client’s name, but the landlord has breached the payment agreement, then the client is protected under the moratorium because the client is the customer of record on the utility bill. Disconnection during Moratorium Regulations allow utilities to disconnect service for a customer otherwise covered under the moratorium in the following circumstances: • If a condition dangerous or hazardous to life, physical safety, or property exists. • Upon order by any court, the Indiana Utility Regulatory Commission (IURC), or other duly authorized public authority. • If fraudulent or unauthorized use of electricity or gas is detected, and the utility has