Page 35

EAP Policy Manual FFY24 Chapter 1 Service Provider Selection and Responsibilities Page 3 • Ensuring timely and accurately reporting, working with fiscal staff as necessary. • Ensuring leveraging activities are reported. eHEAT • Serving as the initial contact and reporting eHEAT related issues to Commerce. • Proficient use of eHEAT and technical assistance to staff and energy vendors. • Ensuring staff are trained to enter program information correctly. Outreach • Coordinating with other community resources, outreach and public relations. Risk Assessment Service Provider management should identify priority activities within the organization for risk assessment, considering areas materially impacting the financial position and results of operations and program (e.g., assets, liabilities, revenues, expenses or expenditures account balances that are material in dollar amount). EAP strives to reduce or eliminate fraud and risk activities through program policies, technical support, program software (eHEAT), segregation of duties, quality controls and monitoring of services and financial activities. Service Provider Business Conflict of Interest Service Providers are required to notify Commerce if their organization operates or owns a business that could be viewed as a conflict of interest with the delivery of EAP. Notification is also required prior to the initiation of a business that could be viewed as a conflict of interest with the delivery of EAP. This may include but is not limited to Service Providers operating as energy vendors, landlords, etc. Such a business relationship and operation requires assurance to Commerce of internal controls to mitigate conflicts of interest. An internal control requirement for Service Providers with this type of business is to have another Service Provider monitor this portion of their operation annually. Conflict of Interest Policy All Service Providers are required to have a conflict of interest policy. A conflict of interest policy for local Service Providers is defined as an actual or perceived action that results or has the appearance of resulting in personal, organizational, or professional gain. Local Service Provider personnel and board members are obligated to always act in the best interest of EAP. At all times, local Service Provider personnel and board members are prohibited from using their job title or the organization name or property, for private profit or benefit. Service Providers are required to