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EAP Policy Manual FFY24 Chapter 7 Assurance 16 Page 17 to verify all participants have been determined EAP eligible if the majority of the class participants are likely to be EAP eligible based on their participation in other low-income programs run by the Service Provider or County (e.g., TANF, SNAP, HeadStart). Proactive ESS Plans must indicate why the Service Provider believes a majority will likely be EAP eligible. Costs for Planning and Preparation Costs for planning and preparation are allowable in some cases and unallowable in other cases. EAP distinguishes between development and implementation costs. Generally, development costs are not allowable, while implementation costs are allowable. Development costs are those for developing, planning, or preparing an activity more generally. For example, completing the A16 section of the EAP Local Plan would be a development cost and the time for this activity would be administrative, and could not be paid for with A16 funds. Similarly, costs for preparing a Proactive ESS Plan would generally be considered an administrative cost and could not be paid for with A16 funds. Conversely, implementation costs are for time planning and preparing for a given session or event. For example, the time to specifically plan for and/or prepare the activities for a specific session on energy conservation would be an implementation cost. As such, these costs would be allowable. Energy Kits The reasonable costs for energy kits may be allowable under specific circumstances. That is, the costs for energy kits included as part of a Proactive ESS Plan may be allowable if the kits are utilized as part of an educational activity. For example, energy kits are provided to households participating in an energy conservation education program. Participants are taught how the items in the kits are used and the associated benefits. As an assignment, participants are tasked with installing a number of the items and reporting back at the next class. Participants are given tools to track how the items impact their energy usage and costs, and provided assistance if they experience challenges installing the items. Other than for use as part of an approved Proactive ESS Plan, Energy kits are specifically not allowable. Examples of when the costs for energy kits are not allowable include: • Energy kits provided to households as a reward for participating in an activity. • Energy kits provided to households as an outreach tool • Energy kits provided as part of a Responsive ESS activity • General distribution of energy kits outside of any A16 activity