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Tennessee Housing Development Agency 2025 LIHEAP Policy Manual for Regular and Crisis Assistance 17

• Original Social Security card; • Verification from the state’s case management and eligibility system (if SSN is listed for the applicant); • Form SSA-1099 (Social Security Benefit Statement); or • Other documentation issued directly by the Social Security Administration (SSA). Not acceptable for SSN verification: • Secondary documentation that merely lists an SSN; • Social Security cards marked “Valid for Work Only with DHS Authorization” or “Not Valid for Employment.” These restricted SSN cards are also not acceptable for determining qualified alien status. In such cases, two forms of documentation—one for identity and one for immigration status— will be required. Acceptable immigration documents are listed in Section 2.5.a.1 – 2. Mixed-Status Households and SSN Refusal

When providing LIHEAP benefits such as energy bill reductions which can reasonably be prorated, LIHEAP grant recipients must prorate such benefits when they are being provided to eligible individuals residing in a household with ineligible members, based on the number of eligible household members. The income of all household members—regardless of eligibility— must be documented, verified, and included in the calculation of the LIHEAP benefit amount. However, ineligible household members must be excluded from the total household count when determining the benefit. If an applicant or household member does not have an SSN, their eligibility is not automatically impacted. If other eligible members exist, benefits may be provided to the household (with restrictions). The income of the undocumented individual is included in the total household income, but they are not counted in the total household size. If a household has an SSN but refuses to provide it, the entire household is ineligible. This includes refusal to provide other documentation required to determine eligibility. Agencies must clearly document whether the SSN is unavailable or simply being withheld. This determination must be included in the written notice to the applicant.

Program Oversight THDA will monitor SSN and citizenship verification policies to ensure consistent application across all local agencies.

2.5 Documentation Required for U.S. Citizens and Qualified Aliens Written or Verbal Requirement: Every state government entity or local health department must include a written or verbal