us-wi/manual/dehcr/wheap-manual

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PY26 WHEAP Manual

1 Revised: August 2025 TABLE OF CONTENTS DISCLAIMER .......................................................................................................... 7 HE+ HELP DESK PROCEDURE ............................................................................... 7 CHAPTER 1 | DEFINITIONS AND ACRONYMS ....................................................... 8 CHAPTER 2 | PROGRAM INTRODUCTION ........................................................... 22 2.1 Program Description WHEAP ............................................................................. 22 2.1.1 WHEAP − Regular WHEAP Benefits ............................................................ 22 2.1.2 WHEAP − Crisis Assistance Benefits ............................................................ 23 2.1.3 WHEAP – HE+ Program Services ................................................................ 24 2.2 WHEAP − General Eligibility ............................................................................... 24 2.3 WHEAP − Regular Benefits Payment Determination ........................................ 25 2.3.1 General Payment Information ....................................................................... 25 2.4 WHEAP – General Emergency Crisis and Prevention Assistance Eligibility . 26 2.5 WHEAP − HE+ HVAC Program Services Eligibility ........................................... 27 2.6 WHEAP − Application Process ........................................................................... 27 2.7 Weatherization Assistance .................................................................................. 28 2.8 Discrimination Complaints and Administrative Hearings ................................ 28 2.8.1 Discrimination ................................................................................................ 28 2.8.2 Hearings ........................................................................................................ 28 CHAPTER 3 | PROGRAM ELIGIBILITY .................................................................. 31 3.1 General Eligibility Rules and Guidelines ........................................................... 31 3.2 Non-Financial Eligibility ....................................................................................... 32 3.2.1 Applicant/Case Head .................................................................................... 32 3.2.2 Residence ..................................................................................................... 32 3.2.3 Social Security Number (SSN) ...................................................................... 35 3.2.4 Student Status and WHEAP Eligibility .......................................................... 38 3.2.5 Energy Burden .............................................................................................. 40 3.2.6 Counting Household Members ...................................................................... 42 3.3 Financial Eligibility ............................................................................................... 44 3.3.1 General ......................................................................................................... 44 3.3.2 Counting Income ........................................................................................... 45 3.3.3 Child Support ................................................................................................ 48 3.3.4 Spousal Impoverishment ............................................................................... 49 3.3.5 Self-Employment Income .............................................................................. 49 3.3.6 Seasonal Workers’ Income ........................................................................... 53 3.3.7 Income Counted Table .................................................................................. 54 3.3.8 Income Deducted Table ................................................................................ 57 3.3.9 Ignored Income Table ................................................................................... 58

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Revised: August 2025 CHAPTER 4 | APPLICATION PROCESS ............................................................... 63 4.1 General Application Rules ................................................................................... 63 4.1.1 How to Apply ................................................................................................. 63 4.1.2 Where to Apply .............................................................................................. 63 4.1.3 When to Apply ............................................................................................... 63 4.1.4 Multiple Applications ..................................................................................... 63 4.1.5 Regular WHEAP Benefits ............................................................................. 64 4.1.6 Weatherization Eligibility ............................................................................... 64 4.1.7 Limitations ..................................................................................................... 64 4.1.8 Fair Hearings ................................................................................................. 64 4.1.9 Application Processing .................................................................................. 65 4.1.10 Fraud Prevention ......................................................................................... 65 4.2 Application Formats ............................................................................................. 66 4.2.1 Interactive ...................................................................................................... 66 4.2.2 HE+ Application (Long Form) ........................................................................ 66 4.2.3 HE+ Recertification Application Form ........................................................... 66 4.2.4 Automated Applications ................................................................................ 67 4.2.5 Phone Applications ....................................................................................... 68 4.2.6 Abbreviated Applications ............................................................................... 68 4.2.7 Online Application ......................................................................................... 68 4.2.8 File Retention ................................................................................................ 69 4.3 Processing an Application .................................................................................. 69 4.3.1 Access ........................................................................................................... 69 4.3.2 Verification of Information ............................................................................. 70 4.3.3 Validation of Applicant Data .......................................................................... 70 4.3.4 Online Application Processing ...................................................................... 70 4.3.5 Updating Applications Created by Another Agency ...................................... 73 4.4 Field-by-Field Instructions/Guidelines ............................................................... 73 4.4.1 Application Date ............................................................................................ 73 4.4.2 Worker Number ............................................................................................. 74 4.4.3 Interactive Interview ...................................................................................... 74 4.4.4 Outreach Indicator ......................................................................................... 74 4.4.5 Withdrawn ..................................................................................................... 74 4.4.6 Social Security Number (SSN) ...................................................................... 75 4.4.7 Field #1 Territory (County/Tribe) ................................................................... 75 4.4.8 Field #2 Applicant (First and Last Name) ...................................................... 75 4.4.9 Field #3 Alias First Name .............................................................................. 75 4.4.10 Field #4 Primary Phone/Secondary Phone ................................................. 75 4.4.11 Field #5 Email Address ............................................................................... 75 4.4.12 Field #6 Preferred Communication ............................................................. 75 4.4.13 Field #7 Housing Type ................................................................................ 75

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3 Revised: August 2025 4.4.14 Field #8 Mailing Address ............................................................................. 76 4.4.15 Field #9 Residence Address ....................................................................... 76 4.4.16 Field #10 Ownership Type: Own or Rent .................................................... 77 4.4.17 Field #11 Room Count ................................................................................ 78 4.4.18 Field #12 Living Situation ............................................................................ 78 4.4.19 Field #13 Is Government Assisted Housing: Rental Assistance ................. 78 4.4.20 Field #14 Guardian Type: Designated Representation ............................... 79 4.4.21 Field #15 Student Situation ......................................................................... 80 4.4.22 Field #16 Is Child Family Housing ............................................................... 80 4.4.23 Field #17 Total # Household Members ....................................................... 80 4.4.24 Field #18 Is Present Month Income ............................................................ 80 4.4.25 First 18 Fields .............................................................................................. 80 4.4.26 Household Members ................................................................................... 81 4.4.27 Household Income ...................................................................................... 82 4.4.28 Energy Fuels (Fuel Page) ........................................................................... 85 4.4.29 Applicant Signature Date ............................................................................ 91 CHAPTER 5 | CRISIS ASSISTANCE ...................................................................... 93 5.1 Introduction .......................................................................................................... 93 5.2 Crisis Assistance Eligibility ................................................................................ 94 5.2.1 General Eligibility Guidelines ........................................................................ 94 5.2.2 Crisis Eligibility − Additional Guidelines ........................................................ 95 5.2.3 Exceptions to the Applicant Contribution Requirement ................................. 96 5.2.4 General WHEAP Agency Responsibilities .................................................... 96 5.2.5 Emergency Crisis Situation ........................................................................... 97 5.3 Crisis Assistance Applications ........................................................................... 98 5.4 Service Types ....................................................................................................... 99 5.4.1 LIHEAP-Funded Service Types .................................................................... 99 5.4.2 Public Benefit Funded Service Types ........................................................... 99 5.4.3 HE+ Program Services Codes ...................................................................... 99 5.4.4 Non-WHEAP-Funded Payment and Services (Additional Services) ........... 100 CHAPTER 6 | QUALITY ASSURANCE ................................................................. 101 6.1 Quality Assurance .............................................................................................. 101 6.2 Desktop Monitoring Agency Responsibilities ................................................. 101 6.3 General Quality Assurance Agency Responsibilities ..................................... 102 6.4 Program Services Quality Assurance Agency Responsibilities .................... 102 6.5 Vendor Desktop Monitoring Agency Responsibilities .................................... 103 CHAPTER 7 | ERRORS, MISTAKES, AND CORRECTIONS ............................... 105 7.1 Updates to Applicant Information ..................................................................... 105 7.1.1 Change in Address ...................................................................................... 105

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Revised: August 2025 7.1.2 Own or Rent ................................................................................................ 105 7.1.3 Fuel Switch .................................................................................................. 105 7.2 Benefit Calculator............................................................................................... 105 7.3 Regular Application Actions ............................................................................. 106 7.3.1 Cancel Benefit (Cancel and Refund) ........................................................... 106 7.3.2 Denied Incomplete ...................................................................................... 106 7.3.3 Updates to Unextracted Applications .......................................................... 107 7.3.4 Denied in Error and Extracted (Reinstate the Application) .......................... 107 7.3.5 Applications in “Paid” Status – “Extracted” State ........................................ 107 7.3.6 Error with an “Extracted” Application ........................................................... 107 7.3.7 Wrong Vendor Entered on Application ........................................................ 110 7.3.8 Deceased Individual .................................................................................... 110 7.4 Automated Applications .................................................................................... 111 7.4.1 Death of Case Head or Household Member ............................................... 111 7.4.2 Change in Household Composition or Income ............................................ 112 7.4.3 Change in the Address (Moved) ................................................................. 112 7.5 Crisis Application Actions ................................................................................. 113 7.5.1 Crisis Paid to a Vendor in Error ................................................................... 113 7.5.2 Crisis Paid to Wrong Account ..................................................................... 113 7.5.3 Crisis Application When Application is Cancelled ....................................... 114 7.5.4 Copayment Agreement Actions .................................................................. 114 7.6 HE+ HVAC Program Services Actions ............................................................. 114 7.6.1 Ownership Change ..................................................................................... 114 7.7 Incorrect HE+ HVAC Program Services or Weatherization Referrals ........... 114 CHAPTER 8 | PAYMENT ADJUSTMENTS, REFUNDS, AND RETURNS ........... 115 8.1 Basic WHEAP Payments ................................................................................... 115 8.2 Payments Sent Directly to the Vendor ............................................................. 115 8.3 Checks Sent Directly to the Applicant ............................................................. 115 8.4 Checks Sent to the Local WHEAP Agency ...................................................... 115 8.5 Payment Registers ............................................................................................. 116 8.5.1 System Codes ............................................................................................. 116 8.6 Check Returns .................................................................................................... 117 8.6.1 Recipient Returns ........................................................................................ 117 8.6.2 When a Notice is Returned by Post Office .................................................. 117 8.6.3 When a Single Party Check is Returned by the Post Office ....................... 117 8.6.4 When a Supplemental Benefit is Returned ................................................. 118 8.6.5 Returned Because the Applicant Is Deceased ............................................ 118 8.6.6 Vendor Identified Incorrect Payments ......................................................... 118 8.7 Refunds ............................................................................................................... 118 8.7.1 Regular WHEAP Benefits ........................................................................... 119

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5 Revised: August 2025 8.7.2 Crisis Benefits ............................................................................................. 120 8.8 Lost, Destroyed, or Stolen Benefit Checks ...................................................... 120 8.9 Overpayments and Applicant Repayments ..................................................... 123 8.10 Bankruptcy ......................................................................................................... 124 CHAPTER 9 | ADMINISTRATION ......................................................................... 125 9.1 Local Administration .......................................................................................... 125 9.2 Program Operations ........................................................................................... 125 9.2.1 General ....................................................................................................... 125 9.2.2 Public Information ....................................................................................... 126 9.2.3 Outreach ..................................................................................................... 127 9.2.4 Agency Information ..................................................................................... 128 9.2.5 Intake .......................................................................................................... 129 9.2.6 Complete and Process Applications ........................................................... 129 9.2.7 Crisis Assistance ......................................................................................... 130 9.2.8 HE+ Program Services ............................................................................... 130 9.2.9 Fraud ........................................................................................................... 131 9.3 Contract and Fiscal ............................................................................................ 131 9.3.1 Payment for Contract Services ................................................................... 131 9.3.2 Out of State Travel ...................................................................................... 132 9.3.3 Computer Equipment, Connections, Security, and Costs ........................... 132 9.3.4 Allowable Costs ........................................................................................... 133 9.3.4.1 LIHEAP Operations Accounts .................................................................. 133 9.3.5 Disallowed Costs ......................................................................................... 135 9.3.6 Performance Measurement ......................................................................... 135 9.4 Financial Standards ........................................................................................... 135 9.4.1 General ....................................................................................................... 135 9.4.2 Source Documentation ................................................................................ 136 9.4.3 Expenditure Documentation ........................................................................ 136 9.4.4 Financial Record Retention ......................................................................... 136 9.4.5 Open Records/Public Records .................................................................... 137 9.4.6 Financial Audits ........................................................................................... 137 9.5 Administrative Requirements ........................................................................... 137 9.5.1 Conflict of Interest Policy ............................................................................. 137 9.5.2 Lobbying Restrictions .................................................................................. 138 9.5.3 General Record Retention .......................................................................... 139 9.5.4 Staffing ........................................................................................................ 140 9.5.5 HE+ System Security .................................................................................. 140 9.5.6 Coordination ................................................................................................ 140 9.5.7 Publications ................................................................................................. 141 9.5.8 Home Energy Plus and Co-Branding Logos ............................................... 141

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Revised: August 2025 9.6 Monitoring ........................................................................................................... 141 9.7 Disaster Planning ............................................................................................... 142 9.7.1 Local Agency Continuity of Operations Plans ............................................. 142 9.7.2 Division Plan ............................................................................................... 142 9.8 Public Benefits ................................................................................................... 144 CHAPTER 10 | CONTRACT INVOICING .............................................................. 145 10.1 General ................................................................................................................ 145 10.2 Invoice Filing Responsibility ............................................................................. 145 10.3 Guidelines for Invoicing .................................................................................... 145 10.4 Reimbursement Payments ................................................................................ 146 APPENDIX A | AGENCY GUIDELINES FOR HANDLING SENSITIVE DATA ..... 147 APPENDIX B | WHEAP APPLICATION INCOME TYPES .................................... 153 APPENDIX C | RENTAL ASSISTANCE FORMS .................................................. 159 APPENDIX D | PROGRAM YEAR (PY) 2026 WHEAP MANUAL SUMMARY OF CHANGES .................................................................................... 162 APPENDIX E | PY26 (2025-2026) WISCONSIN 60% STATE MEDIAN INCOME GUIDELINES ................................................................................ 166 APPENDIX F | HEARINGS AND APPEALS PROCESS FLOW CHART .............. 167 APPENDIX G | AUTOMATED APPLICATION CUSTOMER LETTER TEMPLATE169 APPENDIX H | REQUIRED HE+ SYSTEM NOTES .............................................. 170

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Revised: August 2025 Chapter 1 | Definitions and Acronyms A/C Acronym for air control.

administrative expenses The general costs associated with administrating WHEAP, including direct and indirect costs for: 1. Planning, 2. Determining eligibility, and 3. Issuing benefits.

Adult Family Home (AFH) A licensed, private residential home where 1-4 adults not related to the operator reside and receive care, treatment, or services (that are above the level of room and board). Adult Family Homes, as defined by the Department of Health Services, are eligible dwellings and all household members and their income are to be counted in the application. Caregivers generally receive separate per diems for room and board and care. Any per diem for room and board is ignored, while a per diem for care shall be counted as wages for the caregiver of the household. For additional guidance, please contact the HE+ Help Desk.

agency The term agency, as used in this program, normally refers to the county department, tribal entity, or non-profit organization that administers WHEAP.

annualized income Income calculated to reflect an average monthly amount. Refer to Section 3.3.7 and Appendix B for specific guidance on which income types should be annualized.

applicant The person whose name is entered in Field 2 on the application form (DOA-9549). Applicant and case head are the same and are used interchangeably for purposes of this manual. An eligible case head must have a validated SSN and be a U.S. citizen or an eligible non-citizen. A case head must be 18 years or older, or be a minor head-of-household (see definition), or be a child who meets one of the following exceptions: • All adults in the household are ineligible non-citizens, and: o The dependent child is either a citizen or an eligible non-citizen, and o The child has an SSN, or • An emancipated minor over 15 may be a case head if the minor is living independently, and: o Is married, or o Was married, or o Is principal support of a child, or o Has visible independent means of support and cannot be claimed as a dependent on income tax of someone not in the household

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9 Revised: August 2025 application The form used to apply for energy assistance. The HE+ Application, Form DOA-9549, is the paper form version of the application. • A complete application is an application which has all required information documented and/or verified by the applicant, has been signed and dated by the applicant, has all required information verified by an authorized local agency staff worker, and is signed and dated by the worker. • An incomplete/“Pending” application is an application that is missing one or more of the elements required to be a complete application. • A minimum application is an application that contains at least the applicant’s name, SSN, date of birth, gender, housing type, residence and mailing address, and date of application. This is the minimum to be included to be considered an application for purposes of this program. An application received without an SSN for the case head does not meet the minimum application requirements. • An early application is an application for the upcoming heating season with an application date prior to October 1. Early applications may not be taken until after a date has been determined by the Division. Early applications will not be paid until the first extraction of the new program year. While emphasis shall be given to “fixed income” households, any income type qualifies for an early application. • An automated application is an application processed by the Division/HE+ System. Automated applications are for previous year recipient households whose income is from Social Security and/or Veterans benefits, who have heat and non-heating electricity provided by an IOU, and who have the same household demographics as the previous year. • An online application is an application that is submitted by the customer through the online energy assistance application portal.

application number The application number is an HE+ System-generated identifier attached to an application. This number is used, in part, to ensure the household with the case head is not paid more than one regular heat or electric benefit in a program year.

assisted living facility A living unit where a third party assists the resident with one or more of the resident’s basic daily activities. Basic daily activities include, but are not limited to, meal preparation, food shopping, regular medical care (shots, rehab, etc.), transportation assistance, house cleaning, or home maintenance. See also definition for Adult Family Home (AFH). If the applicant is responsible for energy costs (heat and electric), lives in an independent apartment within an assisted living complex, and pays full market rent, consult the HE+ Help Desk for a determination of the status of the dwelling as an eligible or ineligible assisted living unit.

authorized representative A person who has signed an Affidavit of Agent, and who is listed as the authorized representative on the Authorization of Representation/Affidavit of Agent Form.

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11 Revised: August 2025 DTM Acronym for Desktop Monitoring.

dwelling unit A structure, including a stationary mobile home, apartment, group of rooms, or a single room occupied by a household that has an identifiable site address such as a fire number or street address. A United States Post Office Box number is a mailing address and does not identify a dwelling unit.

early application – See application

Earned Income Tax Credit A refundable federal or state tax benefit designed to help low-income workers increase their financial stability and maintain their independence from the welfare system. It is also known as EITC. For the purposes of WHEAP, it is ignored income.

economic unit A person or group of related or unrelated persons who live together in a dwelling unit and jointly share in providing or being provided for the necessities of life for the person(s) in the group. The necessities of life are shelter, heat, and utilities.

NOTE: Persons living in a housing arrangement with their own room and sharing common spaces and an address are all part of a single economic unit.

elderly household member Individuals who are 60 years old or older as of the application date.

electric burden The responsibility for providing the household for all non-heating electric used in the home.

eligible non-citizen Certain non-citizen statuses are eligible for WHEAP benefits. Eligible non-citizens include those considered one of the categories listed in Section 3.2.2.4 of the WHEAP Manual according to the United States Citizenship and Immigration Services (USCIS).

eligibility determination The process by which a household’s eligibility for WHEAP is assessed. This includes the verification of documentation provided to complete an application and the certification of the correctness of an application.

emergency The actual or imminent loss of essential home heating/electricity during the heating season or during a declared heat emergency in the summer.

Emergency Crisis Assistance Crisis Assistance funds that provide benefits and/or services to address applicant emergencies. Emergency payments are provided during the heating season for households that are experiencing

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Revised: August 2025 actual or imminent losses of home heating/electricity. Emergency payments for cooling assistance are provided during the summer months only in cases of extreme heat and with a declaration of a heat emergency.

Agencies may not implement cooling assistance unless a state or local public health official declares a heat emergency and authorization is given from DEHCR. See Chapter 4.

energy burden The responsibility for providing home energy including home heating and home electricity. For example, a household may purchase fuel from a fuel supplier, make undesignated payments in the form of rent, or may heat with wood, etc.

energy education The process whereby individuals and households learn to make choices to use energy efficiently, improve their indoor comfort, and become aware of how their behavior affects energy consumption, energy cost, and urgent safety concern(s) within their homes.

energy services company (ESCO) Third-party company that manages the energy consumption of multi-unit residential communities, including measuring usage and invoicing the tenants directly.

FFY Acronym for Federal Fiscal Year.

fixed-income household A household that receives only one or more of the following income types: SS including SSDI, SSI, dividends/interest, pension, and/or Veterans benefits.

FO Acronym for fuel oil.

FS Acronym for FoodShare (SNAP).

fuel supplier A fuel supplier is an individual, partnership, or corporation in the business of supplying energy to customers. Landlords, trailer park owners, and other persons who purchase home energy from a fuel supplier to provide tenants or homeowners with home energy are not considered fuel suppliers.

government-assisted housing Housing where tenants pay less than the full costs for their residence because the federal, state, or local government pays a portion of their rent. These housing units limit the tenant rent responsibility to no more than 30% of their income and is usually subsidized by the Department of Housing and Urban Development (HUD). Government-assisted housing includes Section 8, rental assistance, subsidized housing, and most other programs to make housing more affordable to

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Revised: August 2025 • A public or private place not designed for use as a regular sleeping accommodation for human beings

household (HH) Any person or group of persons living together in a dwelling unit on the application date who directly purchase home energy or make undesignated payments for energy in the form of rent. See also dwelling unit and economic unit.

household member Anyone who, on the date of application, is living in the household and who is not a temporary household member or considered a household member not included on the application as listed in Section 3.2.6.4. Household members who are temporarily out of the household on the date of the application for reasons such as a vacation or a business trip are still considered part of the economic unit and are counted on the HE+ Application. In addition, those working out of town and not maintaining a separate permanent residence are also considered part of the economic unit. Do not count a person who may have lived in the household during a portion of the prior month but is no longer in the household on the application date; do not count the person or their income to determine total household size or income. A household member with multiple residences shall be included in the household if this is their primary residence. When a household member resides in more than one residence, the WHEAP agency must indicate in HE+ System Notes on what basis they determined the primary residence.

HVAC Acronym for heating, ventilation, and air conditioning.

income All monies received by a household. See Chapter 2 for an explanation of which monies are counted as income and which are ignored.

Incomplete Notification/Notice A system-generated incomplete notification created for pending applications to notify customers of missing information. When selecting mail or email notification type, the agency must mail or email the notification to the customer directly as it is not system generated.

indirect cost Expenses of conducting business that are not readily identified with providing services. Indirect costs mean the same thing as overhead costs.

ineligible dwelling unit Ineligible dwelling units are units that are not eligible to receive WHEAP benefits. Mobile shelters are ineligible dwellings, and typically include, but are not limited to, tents, campers, and vehicles. Group homes, halfway houses, government facilities (jails, hospitals, and other governmental care facilities), assisted living facilities, transitional housing facilities, abandoned spaces or buildings, and secondary homes are also ineligible dwelling units for WHEAP. WHEAP agencies should contact the HE+ Help Desk when questioning an ineligible dwelling.

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15 Revised: August 2025 ineligible non-citizen Certain non-citizen statuses are ineligible for WHEAP benefits. Ineligible non-citizens include individuals without a USCIS status and non-citizens who do not meet one of the specified categories outlined in Section 3.2.2.4 of the WHEAP Manual.

Informational Transmittal (IT) A correspondence sent from the Division to notify WHEAP agencies of policy and process changes throughout the program year (PY). Updates sent via IT shall supersede policy and guidelines printed in the current year manual. To receive ITs via email, the agency staff HE+ System Contact must be assigned one of the following roles: “Director,” “Coordinator,” and/or “Fiscal.” Staff without one of these HE+ System roles assigned may access the current and prior year ITs on the HE+ TTA website.

in-kind rental agreement Living arrangement where instead of paying rent, the landlord provides a living space and in return the renter completes a working arrangement with the landlord instead of receiving (full) wages.

intake The process of taking an application to be used for determining eligibility for assistance.

interactive interview An interview with the applicant answering questions as the information is being entered into the HE+ System.

IOU Acronym for investor-owned utility.

KWW/CF Acronym for Keep Wisconsin Warm/Cool Fund.

Low Income Home Energy Assistance Program (LIHEAP) The federally designated program under 42 U.S.C. 8621. The program provides benefits and services to assist low-income households with the costs of energy used for home heating. This federal program has also been referred to as LIHEAP.

NOTE: DEHCR calls its program WHEAP including the federally funded LIHEAP program and the Wisconsin PB program. See also Public Benefits.

Low-Income Housing Tax Credit (LIHTC) housing (also known as “Section 42”) Based on Section 42 of the Internal Revenue Code, this housing program was enacted by Congress to provide the private market with an incentive to invest in affordable rental housing. Tenants of LIHTC housing receive a small reduction in rent from the market rent value. Because the tax credits were awarded to the builder/owner, tenants of LIHTC housing are not considered residents of government-assisted housing.

LP Acronym for propane (liquid propane).

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Revised: August 2025 MCI Acronym for Master Customer Index (used for SSN verification).

minimum application – See application

minimum benefit For administrative reasons, benefit calculations for amounts under $30 are not issued a payment. Minimum benefit payment must equal $30 or greater for the regular or crisis benefits to be issued. When the regular benefit calculation is under the minimum benefit amount, the HE+ System will generate a denial notice stating that “Your heating benefit does not meet the minimum benefit (effective FFY2013 $30 minimum). Benefit checks are not issued for amounts below the minimum.” An applicant is eligible for funding under that associated benefit (heat or PB) if the agency wishes to issue crisis for that fuel type.

minor head-of-household A minor (under age 18) who has Head-of-Household filing status for tax purposes. See also applicant for relevancy to WHEAP.

mobile home A manufactured home designed to be towed to a permanent residential site as a single unit or in sections and is equipped and used, or intended to be used, primarily as a year-round dwelling, with walls of rigid un-collapsible construction.

A mobile home continues to be classified as a mobile home even when additions have been made to the structure.

NG or NA Acronym for natural gas.

naturalized U.S. citizen Naturalization is the process by which U.S. citizenship is granted to a foreign citizen or national after he or she fulfills the requirements established by Congress in the Immigration and Nationality Act (INA). Naturalized U.S. citizens can provide a Naturalization Certificate or U.S. passport as evidence.

net operating loss (NOL) Individuals can carry over business loss from a previous tax year if the total loss was more than what would reduce taxable income to zero in that prior tax year. The remaining loss balance not used in the initial year of loss can be applied to a future year to offset that year’s taxable income. This is a tax benefit policy – the NOL should not be considered as a genuine loss for the tax year – it is essentially a tax credit but entered on the Schedule 1’s income section.

non-citizen A non-citizen is a person who is not a citizen of the United States. Non-citizens may or may not be eligible for WHEAP benefits.

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19 Revised: August 2025 self-employment (SE) income Income, including self-employment, odd jobs, or farm income, that is received directly from one's own business or means rather than as an employee with a specified salary or wage from an employer.

S-GIRF Acronym for Self-Generated Income Report Form.

spouse A person who is defined as married under Wisconsin law.

SSN Acronym for Social Security number.

State The State of Wisconsin.

state median income (SMI) An income level determined to be the median for households (four-person) in the state. This number is used as a reference point from which to calculate the maximum income level eligibility for households.

subsidized housing Programs operated under the U.S. Housing Act of 1937, the National Housing Act, Section 101 of the Housing and Urban Development Act of 1965, Section 202 of the Housing Act of 1959, Title V of the Housing Act of 1949, or any program listed in the most current State of Wisconsin Inventory of Federally Assisted Rental Housing and the Housing Authority Directory. See also government- assisted housing.

subsidized-housing utility allowance In government-assisted housing, the portion of a subsidized housing resident's rent that is applied to heating and/or electric costs, or the amount of rent reduction to permit the resident to directly pay heating and/or electric costs. Do not count sub-housing utility allowances as income.

subsidized-housing utility reimbursement Payment issued by the housing authority either to the tenant or directly to the utility on behalf of the tenant to assist with payment on their heat/utility costs. Do not count sub-housing utility reimbursement as income.

supplemental benefit A special heating or electrical assistance payment provided in addition to, or as a second part of, the original heating or electrical assistance benefit.

Temporary Assistance for Needy Families (TANF) Title I of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). The federal block grant program that provides states with the authority and funding to create programs that provide time-limited assistance to needy families with children and promote work.

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Revised: August 2025 temporary household member Anyone who is not a permanent resident in the household, whose stay in the household will be less than 30 days beyond the application date. The applicant certifies the temporary household member is not going to be in the home for more than 30 days.

test period Prior month income.

transitional housing Housing facility used to assist the movement from homelessness to independent living. Structure may be an SRO (single room occupancy) building, a congregate living facility, a group home, a regular apartment, or a single-family dwelling. If the applicant is responsible for energy costs (heat and electric), consult the HE+ Help Desk for a determination of the status of the dwelling as a transitional housing unit.

T&TA Acronym for Training & Technical Assistance.

U.S. citizen A person (other than the child of a foreign diplomat) born within the United States or in the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, or the Northern Mariana Islands who has not renounced or otherwise lost his or her citizenship, a person born outside of the United States to at least one U.S. citizen parent (sometimes referred to as a “derivative citizen”), or a naturalized U.S. citizen.

VDTM Acronym for Vendor Desktop Monitoring.

WAP Acronym for Weatherization Assistance Program.

Weatherization (Wx) The improvement of a dwelling unit to reduce energy consumption. It often includes the installation of insulation and replacement or modification of the heating system.

Weatherization operator An agency that contracts directly with the State to provide Weatherization services for low-income households.

winter moratorium The period from November 1 through April 15.

Wisconsin Emergency Rental Assistance (WERA) Started in PY21 and will end on or before December 31, 2025.

Wisconsin Energy Fuel Information (WEFI) Online utility account verification system used by the state’s five largest investor-owned utilities:

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Revised: August 2025 Chapter 2 | Program Introduction 2.1 Program Description WHEAP WHEAP is an umbrella term covering two different but very similar programs. LIHEAP is a federal program established to provide financial assistance for fuel costs for low-income households. The PB program was originally created in 1999 as part of Wisconsin’s biennial budget bill. Under this program, a low-income fund was created into which the electric providers in the state contribute an amount primarily generated by a fee added to customers’ electric bills. The money in this fund is divided between the energy assistance program and the Weatherization Assistance Program (WAP). A provision of this law permits cooperative and municipal utilities to operate a Commitment to Community Program instead of participating in the PB fund. The customers of utilities choosing to operate a Commitment to Community Program are not eligible for energy assistance or weatherization benefits from the PB program. These customers may be eligible for LIHEAP- funded program services.

Both LIHEAP and PB are designed to assist eligible households with their heating and electric bills and have very similar functions and design with the major difference being that LIHEAP focuses mostly on heating assistance and PB provides benefits for non-heating electric consumption.

The two basic parts of energy assistance are Regular WHEAP Benefits and Crisis Assistance. In addition, an HE+ HVAC Program Services program is operated under WHEAP.

WHEAP benefits are not guaranteed to eligible households. When funds have been exhausted for a program year, there are no benefits issued to households regardless of eligibility.

Throughout the WHEAP Manual you will often see “heating season.” Wisconsin state statute 16.27 (4)(a) defines Wisconsin’s heating season as October 1 through May 15. Applications processed between May 16 through September 30 are not eligible for Regular WHEAP Benefits, yet if otherwise eligible may be considered for Crisis Assistance and other HE+ programs (see Chapter 5).

2.1.1 WHEAP − Regular WHEAP Benefits Regular WHEAP Benefits provide assistance with current season heating (LIHEAP) and/or non- heating electric (PB) expenses. Regular WHEAP Benefits are provided on behalf of eligible households to the fuel vendor (utility or deliverable fuel vendor) or, in a limited number of situations, directly to the applicant. Households may be eligible for one or both of the benefits. Applicants may receive only one regular heat and/or one regular electric (non-heating) benefit during each heating season. Regular WHEAP Benefits are paid out of a central account managed by DEHCR.

Regular WHEAP Benefits are not intended to cover the total costs of heat or electricity. Regular WHEAP Benefits may only be applied to the current heating season or program year. Some of the factors affecting the amount of the heat benefit include: • Total funding available for Regular WHEAP Benefits in the state • The income (reference Chapter 3) level of the household

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23 Revised: August 2025 • Type of fuel • The number of rooms in the dwelling unit • The fuel costs of the household • The type of dwelling unit

Regular electric (non-heating) benefits are only available to households served by a utility that participates in the State Public Benefits program. Some of the factors affecting the amount of the electric benefit include: • Total funding available for Regular WHEAP Benefits in the state • The income level of the household • The electric (non-heating) fuel costs of the household

Electric costs shall be entered on the application even if the household is not served by a PB participating vendor.

Vendors that do not participate in the PB program administer their own assistance program which is referred to as the Commitment to Community Program. Applicants with vendors that do not participate in the PB program must contact their vendor if they wish to apply for assistance from the Commitment to Community Program.

2.1.2 WHEAP − Crisis Assistance Benefits Crisis Assistance, whether LIHEAP or PB, is intended to allow the local WHEAP agency to respond to special situations by dealing with emergency situations or acting proactively to avoid serious problems. Crisis Assistance is a discretionary benefit to households; even if a household is eligible, they may not receive assistance.

Crisis Assistance is categorized by two payment types: emergency and Prevention Assistance. The eligibility requirements for each are slightly different. Emergency payments are only available during the heating season (October 1 to May 15). Prevention Assistance payments are available any time during the program year (October 1 to September 30). Prevention Assistance payments can be made on applications where the applicant meets the financial and non-financial eligibility, but the application denied because the application is dated after the heating season.

Crisis Assistance benefits are only paid to providers of goods or services. Applicants never directly receive the benefits.

Crisis Assistance benefits are paid from a central account managed by DEHCR.

2.1.2.1 WHEAP − Crisis Assistance Services Crisis Assistance Services funds are provided to local WHEAP agencies to provide a mechanism for purchase of services (such as education – energy or financial) and goods (such as weatherization kits) for recipients. These funds may also be used to cover local agency costs of taking and processing applications for Crisis Assistance.

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Revised: August 2025 2.1.3 WHEAP – HE+ Program Services HE+ HVAC Heating Program Services: Eligible households whose primary heating system no longer provides heat, is inoperable, or becomes unsafe may be eligible to receive services.

HE+ Water Conservation Program Services: Eligible households who are in need of repair or replacement of leaky or non-working water heaters, leaky fixtures, toilets, and/or piping.

The local WHEAP agency must determine eligibility for HE+ Program Services before services are provided. HE+ Program Services are a discretionary benefit to households; even if a household is eligible, they may not receive services.

The HE+ Program Services eligibility criteria and service requirements are outlined in the HE+ Program Services Manual (available on the Division website). The HE+ Program Services Manual outlines when a repair or replacement is appropriate.

Services provided to a household through HE+ Program Services and in conformance with the HE+ Program Services Manual requirements will never result in a property lien or in a charge to the eligible household.

HE+ Program Services payments are paid from a central account managed by DEHCR.

2.2 WHEAP − General Eligibility There are financial and non-financial parts to the eligibility determination. Non-financial eligibility criteria include Wisconsin residence, eligibility to receive federal benefits (for non-citizens), provision of a SSN, having an energy burden, and other issues. Detailed discussion of non- financial eligibility requirements is presented in Chapter 3.

Financial eligibility requires a household’s income to be less than or equal to sixty percent (60%) of the state median income (SMI). The income levels for various family sizes are published by DEHCR at the beginning of the heating season. The HE+ Program uses a one-month income test which is annualized to determine program income eligibility. The test period for determining the income level for the household is usually the one month prior to the month of application. If an agency determines that a household’s prior month income exceeds the WHEAP eligibility limit, and the household’s financial circumstances have recently changed, the agency may use the present month income to establish eligibility. See Section 3.3.2 for more information. The income for certain income types, such as seasonal wages and self-employment income, have a test period that is based on income received during the 12 months prior to the date of the application, or the previous tax year. A detailed discussion of financial eligibility is presented in Chapter 3.

When a household is found to be eligible for Regular WHEAP Benefits, the determination of eligibility is used for Crisis Assistance and HE+ Program Services for the remainder of the program year (October 1 to September 30). Application eligibility does not continue for the remainder of the program year if either the case head or a household member is deceased. A new application shall be processed to establish eligibility for the remaining household members. Crisis Assistance and

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25 Revised: August 2025 HE+ Program Services have additional eligibility criteria that also must be met. When HE+ Program Services are requested and the applicant resides at a different address from the one on the parent application, a new application shall be processed to determine eligibility for that building. See Chapter 3, Chapter 5, and Section 7.3.8, and the HE+ Program Services Manual.

2.3 WHEAP − Regular Benefits Payment Determination WHEAP heat benefits are primarily based on the relationship of household income to the state median income (SMI), size of the dwelling (number of rooms), dwelling type, and home energy costs. The primary factors affecting the regular electric (non-heating) benefit are the household income and the non-heating electric use. A table of the maximum income allowable for various family sizes is provided on the Division website. The table is also available in the WHEAP brochures sent to the agencies.

2.3.1 General Payment Information Regular WHEAP Benefits are provided to eligible households for almost any type of heating fuel used – natural gas, fuel oil, liquefied petroleum gas (propane), wood, wood pellets, corn pellets, and some other fuel types. The HE+ System calculates the Regular WHEAP Benefit amounts based on the information submitted in the application. The primary factors affecting the benefit level are household income, number of household members, fuel type, fuel use, and number of rooms in the dwelling.

The information entered in the Energy Usage section of the HE+ Application must be the reported cost of the household’s primary heating fuel usage and electric costs. In cases where electric is used for primary heat, total electric costs only need to be entered once.

The HE+ System calculates the benefit for heating and non-heating electric assistance when the application is submitted. The HE+ System generates benefit payments to vendors or customers, and notification letters to customers. The notification letters indicate: 1) the type of benefit(s); 2) the benefit amount(s); 3) the recipient of the benefit; 4) if the benefit has been withdrawn, cancelled, or denied along with the denial reason and/or repayment amount (when applicable); and 5) appeal rights. No payments will be issued for benefits that are calculated at less than $30.

1. Income The HE+ System calculates the household income level. If a household’s income level is less than or equal to 60% of the state median income (SMI) level, the household is income eligible. If the household’s income level is more than 60% of the SMI level, the household is denied WHEAP benefits as over-income, unless the household has been deemed categorically eligible. When a categorically eligible household is over 60% SMI, the benefits are paid as if the applicant’s income is 60% SMI. 2. Energy Costs To receive a benefit based on actual costs, the bill for home energy costs must be a direct pay account and cannot include charges for a business or from a shared meter (see Chapter 4 for additional limitations on using actual fuel costs). The HE+ System uses the home energy information entered in Energy Usage section of the application to determine heating and non-heating electric costs. If annual fuel usage is not provided during the

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Revised: August 2025 application process, benefits will be based on the proxy fuel table. When an amount is used from the proxy table to calculate benefits, the fuel use is set at 75% of the projected average cost for the fuel and building type.

The information entered in the Energy Usage section of the application must be the reported cost of the household’s primary heating fuel usage and electric costs. In cases where electric is used for primary heat, total electric costs only need to be entered once. 3. Comparisons to Heat Proxy Table The HE+ System automatically compares adjusted actual heating costs to the Heat Proxy Fuel Table. The heat proxy amount is based on 75% of the average costs for the same dwelling type, fuel type, and number of rooms. a. If the adjusted actual heating costs are greater than two times the proxy for the same dwelling type, fuel type, and number of rooms, benefits will be based on two times the proxy amount, rather than actual costs. b. If the adjusted actual heating costs are less than the proxy, benefits will be based on the proxy rather than actual costs. 4. Proxy Fuel Tables There are situations where actual fuel costs are not available for calculating benefits, such as heat included in rent. To permit calculation of WHEAP benefits, an amount is taken from the appropriate proxy table. Each table is a collection of average costs. There are a number of tables to provide numbers based on fuel type and other factors, such as the number of rooms and the fuel used for making hot water. 5. Heat Proxy Table When annual cost is zero, the HE+ System uses the appropriate amount from the Proxy Fuel Table to calculate the benefit.

The HE+ System reduces the appropriate average heating cost by 25% as an incentive to use actual fuel costs. 6. Electric Proxy Tables When annual cost is zero, the HE+ System uses the appropriate amount from the Proxy Electric (PB) Table to calculate the benefit. When electric is the only fuel source for the dwelling, the non-heating electric portion is determined by reducing by half the total reported consumption to determine the amount used in calculating the electric benefit (if the applicant is a customer of a Public Benefits participating utility). 7. Number of Rooms The HE+ System uses the number of rooms in a dwelling as a measure of the size of the dwelling. In counting the number of rooms, there are areas that are not counted such as bathrooms, unfinished basements, entryways, hallways, laundry rooms, porches, closets, and unheated attics. The maximum number of rooms allowed in the HE+ System is nine (9). See Section 4.4.17 for information on counting the number of rooms.

2.4 WHEAP – General Emergency Crisis and Prevention Assistance Eligibility To receive Crisis Assistance, households must be eligible for WHEAP as established by an HE+

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27 Revised: August 2025 Application. Customers must have a need for Crisis Assistance and a direct pay relationship with a participating energy vendor. Customers must have paid at least $25 in the past three months on the energy account for which they are seeking Crisis Assistance. There is a maximum crisis benefit amount that a customer may receive during a program year (October 1 to September 30), and they cannot receive WHEAP Crisis Assistance more than two times during a program year. Agencies may contact the HE+ Help Desk to request an exception to the customer contribution requirement or the maximum crisis benefit amount. See Section 5.2 for more information.

2.5 WHEAP − HE+ HVAC Program Services Eligibility Homeowners and some renters who are WHEAP eligible may be eligible for HE+ Program Services. Homes owned by a business are generally not eligible for HE+ Program Services. Exceptions to this shall receive prior approval from the HE+ Help Desk. See the HE+ Program Services Manual for details.

2.6 WHEAP − Application Process The application for WHEAP benefits is called the HE+ Application. This application is also used to determine eligibility for Weatherization Assistance.

Individuals must apply for energy assistance through an approved WHEAP agency for the county/tribe where they reside or online. There is an approved WHEAP agency for each county and for six of the tribes in the state.

Individuals may submit multiple applications during the program year, October 1 to September 30. An applicant may only receive one regular heat benefit and one regular non-heat electric benefit each program year. However, being turned down for benefit(s) during a program year does not preclude future applications during the program year. If circumstances have changed since the “Denied” application, a new application can lead to an award of benefits.

Applicants must provide complete and accurate information for their household within 30 days of the application date. The Certification Page provides notice to the applicant regarding use of the information provided and the rights of the applicant. By submitting the application, the intake worker acknowledges that they have verified the applicant’s information and agree to comply with the HE+ Conflict of Interest/Non-Disclosure Agreement (see Section 9.5.1.1).

Telephonic signatures are allowed to satisfy the Certification Page requirements. A telephonic signature is a recording of the entire Certification Page being read to the customer and the customer acknowledging the statement associated with their signature. This recorded telephonic signature shall be uploaded to the HE+ System Certification Page repository.

Email, text, and/or mail are other acceptable methods to satisfy the Certification Page requirements. The signed Certification Page shall be uploaded to the HE+ System Certification Page repository.

Exceptions may be granted for obtaining a customer signature due to illness or other extenuating circumstances including lack of access to printers/scanners. Agencies shall contact the HE+ Help Desk to obtain an exception on a case-by-case basis.

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Revised: August 2025 Online applications do not have a physical Certification Page. When customers apply using the online application, they are provided with the Certification Page language prior to submission. The HE+ System records the date and time the customer “signs” and submits the online application.

2.7 Weatherization Assistance The HE+ Application is used for both the energy assistance and Weatherization Assistance programs. Both programs have the same basic eligibility requirements, so a single application can be used for both.

2.8 Discrimination Complaints and Administrative Hearings 2.8.1 Discrimination If an applicant believes they have been discriminated against in any way, the applicant may file a complaint by contacting the Coordinator of the agency where they applied, or any person authorized by the agency to receive discrimination complaints. Federal law prohibits discrimination based on race, color, national origin, sex, age, or disability.

2.8.2 Hearings An individual has the right to apply for energy assistance benefits and to receive a payment or a letter of explanation within 45 days from the date the application process is completed. The application process is not complete until the HE+ System processes the application (determines eligibility, calculates a benefit, and sends a notice of award or denial). If the applicant believes their application has not been processed timely, has been incorrectly denied, or their payment is incorrect, they have the right to request a fair hearing.

The fair hearing process is designed to ensure that customers receive fair consideration and appropriate assistance. It is intended to resolve disputes reasonably and should be processed using the following three steps: • Step 1: Customers contact the agency that processed the application to request an appeal • Step 2: Formal appeal to DEHCR • Step 3: Appeal to the Division of Hearings and Appeals (DHA) Division of Hearing and Appeals PO Box 7875 Madison, WI 53707-7875

Customers may not follow all three steps in order and may start their appeal at any point in the process. Regardless of whichever step a customer starts their appeal, the WHEAP agency and DEHCR should work together to resolve the dispute quickly and ensure that customers receive fair consideration and appropriate assistance.

General Fair Hearing Procedures Customers may initiate an appeal if they believe: • The regular application was incorrectly denied, incorrectly processed, and/or not processed in a timely manner

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29 Revised: August 2025 • The crisis request was not processed in a timely manner

The customer may withdraw an appeal at any time during the process with written notice.

Step 1: Local WHEAP Agency Appeal Customers have 15 days after they receive their notification letter to contact the local WHEAP agency to request an appeal. The customer contact may be initiated in writing or by telephone. In most instances, customers request an explanation regarding income, eligibility, and/or benefit determination. WHEAP agencies shall work with customers and try to resolve the issue(s) prior to submission of a request for an appeal to the Division. The WHEAP agency shall provide a response to the customer within five (5) days of the initial customer contact. Agencies may contact the customer via email, phone, and USPS letter. If the customer is not satisfied with the WHEAP agency’s response, the customer may submit a written formal appeal to the Division. WHEAP agencies shall maintain a log of all appeals and add HE+ System Notes to summarize the appeal. Agencies shall make the log available upon the Division’s request.

Step 2: Division Formal Appeal Customers may use the DEHCR Appeal Form or a letter to the Division to submit their request for an appeal. The DEHCR Appeal Form is found on the Division website for customers. It is available in English, Hmong, and Spanish. If a customer opts to send a letter instead of using the form, the letter shall include a short statement of the matter to be reviewed. The completed DEHCR Appeal Form can be emailed to the HE+ Help Desk at heat@wisconsin.gov or sent via mail to:

DOA/DEHCR Attn: Fair Hearing PO Box 7970 Madison, WI 53707

WHEAP agencies shall assist the customer with submitting a written appeal, if requested. At a minimum, the WHEAP agency shall provide the customer with the DEHCR Appeal Form and the address of where the form/letter should be submitted.

When the Division receives an appeal, Division staff will: • Notify the customer the appeal has been received • Notify the WHEAP agency that an appeal has been received • Log the appeal and add HE+ System Notes

After being notified by the Division of the DEHCR-level appeal, the WHEAP agency will complete the following: • Review the details relevant to the appeal • Check compliance with the WHEAP policies, procedures, and applicable statutes • Contact the customer verbally and in writing via email when applicable and take appropriate action to address the appeal concern, HE+ System Notes are required of contacts made to the customer • Respond to the Division within 2 business days with a summary of their actions

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31 Revised: August 2025 Chapter 3 | Program Eligibility 3.1 General Eligibility Rules and Guidelines The HE+ Application is used to process regular energy assistance benefits, establish eligibility for Crisis Assistance, and establish eligibility for WAP. HE+ Applications are submitted online, by phone with either the local WHEAP agency or the statewide Customer Care Center, by mail, or in- person with the local WHEAP agency. The eligibility criteria for WHEAP and WAP follow the same guidelines – the income limits are the same; however, WAP has structural criteria that may include or exclude a dwelling unit which means while the household may be eligible, the dwelling could be ineligible.

Eligibility is based on non-financial and financial requirements. The applicant must meet both sets of requirements to be eligible for energy assistance. Financial and non-financial eligibility criteria are assessed based on household composition and circumstances on the date of application for energy assistance.

Households denied a heating benefit or a PB (electric) during the heating season may reapply for the denied benefit if the conditions leading to denial of that benefit (heat or electric) have changed. A household may re-apply multiple times if not deemed eligible on earlier applications. Households may apply throughout the year for eligibility. Households applying after May 15 will not be eligible for Regular WHEAP Benefits but should be encouraged to complete their applications. While applications dated after May 15 will be denied for Regular WHEAP Benefits because they were submitted after the end of the heating season, eligible households may still receive Prevention Assistance, HE+ Program Services, and/or Weatherization services. If a customer contacted an agency to apply for WHEAP on or before May 15 but faced challenges in scheduling an appointment prior to May 15, their application may be backdated to May 15 as long as the application is completed between May 16 and June 15. A required HE+ System Note explaining why the application was backdated to May 15 and the date the customer contacted the agency shall be added. An online application in any status other than “submitted” is not considered to be contact or attempted contact with the WHEAP agency.

An applicant is eligible for only one heating and one electric benefit per heating season. Applications must be entered/processed in the chronological order in which they were received. The application completed with the first chronological date, when more than one application from an applicant exists, will have precedence in processing.

There is no entitlement to WHEAP or WAP benefits; being eligible does not mean Regular Benefits, Crisis Assistance, HE+ Program Services, or Weatherization Assistance will be provided.

Households containing an individual who was a case head on a “Paid” application during the current heating season are not eligible for regular heating/electric benefits. However, such a household may be considered for Crisis Assistance if all other eligibility requirements are satisfied.

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Revised: August 2025 3.2 Non-Financial Eligibility Non-financial eligibility includes several types of tests, and households must satisfy the requirements of each test. These tests include residence, citizenship or immigrant status, valid SSN, student status, and energy burden.

3.2.1 Applicant/Case Head An eligible case head must have a validated SSN and be a U.S. citizen or an eligible non-citizen. If the case head is an ineligible non-citizen, the application will deny. The HE+ System automatically generates a letter stating that the household was denied. If there is an eligible non- citizen or U.S. citizen of any age in the household, the worker must encourage that person to apply (become the case head).

A case head must be 18 years or older, or be a minor head-of-household, or be a child who meets one of the following exceptions: 1. All adults in the household are ineligible non-citizens, and: a. The dependent child is either a citizen or an eligible non-citizen, and b. The child has an SSN, or 2. An emancipated minor over 15 may be a case head if the minor is living independently, and: a. Is married, or b. Was married, or c. Is the principal support of a child, or d. Has visible independent means of support and cannot be claimed as a dependent on the income tax return of someone not in the household

3.2.2 Residence A person who lives in Wisconsin and makes Wisconsin their principal residence meets the Wisconsin portion of the residence requirement. They must also intend to remain in Wisconsin.

A person must apply for energy assistance where they are residing in Wisconsin. An applicant/household member with multiple residences must apply based on their primary residence. When an applicant/household member resides in more than one residence, the local WHEAP agency must indicate in HE+ System Notes on what basis they determined the primary residence. Applications for an address that has been determined to not be the primary residence will deny as an “ineligible dwelling.”

Applicants who already received LIHEAP assistance in another state are not Wisconsin residents for the same heating season.

3.2.2.1 Type of Residence Only applicants living in an eligible dwelling are eligible for WHEAP benefits. If a dwelling is not listed in Table 3.1 below, workers shall contact the HE+ Help Desk for assistance in determining the eligibility of a dwelling. If an applicant resides in a motel, hotel, or a stationary RV or camper,

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33 Revised: August 2025 the worker shall contact the HE+ Help Desk to determine if the applicant resides in an eligible dwelling.

Table 3.1: Dwelling Eligibility Eligible Dwellings Ineligible Dwellings Single family house (may include some non- standard dwelling types) Secondary home (e.g., vacation home, seasonal home) Multi-unit building with two (2) or more units (e.g., duplex, condo, apartment, townhouse, studio apartment, flat) Vehicle Mobile home Assisted living facility or nursing home Adult Family Home (as licensed by the Wisconsin Department of Health Services) Group home, halfway house, most motel and hotel situations*, all YMCA/YWCA, Community- Based Residential Facility (CBRF), or foster home**

Government or institutional facility (e.g., jail, hospital, care institution)

Deer stand

Abandoned building or space

Tent

A home rented through Airbnb or similar service for short-term rentals*** *Must be primary residence and have an energy burden. Agencies must contact the HE+ Help Desk for approval for all applicants residing in a motel or hotel. **This refers to a foster group home or similar facility, not a private family household that includes foster child(ren). ***The owner of a home rented through Airbnb or similar service may be eligible if the owner lives in the home full-time and is income eligible.

3.2.2.2 Roomers A roomer is a person who rents a sleeping room and shares common living space and a common address with others in the household. While a roomer may not share in providing, or being provided for, the necessities of life with others living in the residence, they are still part of the same economic unit for the purposes of WHEAP because they share an energy burden.

3.2.2.3 Homeless A homeless applicant who has proof of a permanent address they will be moving into may be eligible for an energy assistance benefit if the following conditions are met: • Verification of a move to a permanent address. This should be verified by a lease agreement, phone call to the landlord, or information from a homeless shelter. • The applicant must have selected a vendor to provide service in their new residence unless energy service is included in the rent or paid to the landlord in a separate payment.

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Revised: August 2025 • If the homeless applicant cannot secure a home energy account due to large arrearages on a previous account, or does not have the money for a deposit, prevention services may be used to assist them with securing energy services.

It may be necessary for the local WHEAP agency or a homeless shelter to assist the applicant in gathering information or obtaining a current vendor and an account number.

3.2.2.4 Non-citizens If an individual is not a U.S. citizen, they shall be identified as either an eligible or ineligible non- citizen for WHEAP benefits.

If the applicant states a household member does not have an SSN or valid immigration records, the individual shall be marked an ineligible non-citizen. This individual may not be the case head of the application. See Section 3.2.1 and Section 3.2.6.2 for more information.

Before a non-citizen is marked an eligible non-citizen on the HE+ Application, the local agency intake staff must complete the following steps: 1. Run the provided SSN through the verification process. The SSN must be positively verified before proceeding to the next steps in eligibility determination. 2. If the SSN has been verified, verify if the individual is receiving FoodShare or any form of monthly Social Security income. a. If yes to either, mark the individual an “Eligible Non-citizen” and document in HE+ System Notes the method of verifying receipt of FoodShare or Social Security income. b. If no, each individual must be defined as one of the following categories, according to the United States Citizenship and Immigration Services (USCIS), in order to mark an eligible non-citizen: i. A non-citizen lawfully admitted for permanent residence under the Immigration and Nationality Act (INA) ii. A non-citizen granted asylum under section 208 of the INA iii. A refugee admitted to the United States under section 207 of the INA iv. A non-citizen paroled into the United States under section 212(d)(5) of the INA for at least one year v. A non-citizen whose deportation is being withheld under section 243(h) of the INA as in effect prior to April 1, 1997, or whose removal is being withheld under section 241(b)(3) of the INA vi. A non-citizen granted conditional entry pursuant to section 203(a)(7) of the INA as in effect prior to April 1, 1980 vii. A non-citizen who is a Cuban or Haitian entrant as defined in section 501(e) of the Refugee Education Assistance Act of 1980 viii. A non-citizen who (or whose child or parent) has been battered or subjected to extreme cruelty in the United States and otherwise satisfies the requirements of § 431(c)

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35 Revised: August 2025 ix. Amerasians under the Amerasian Immigration Act of 1982 x. Native Americans born abroad xi. Trafficking victims who have been classified with a T nonimmigrant status xii. Compact of Free Association (COFA) citizens An individual meeting one of the above categories must provide one of the following forms of documentation. It is the applicant’s responsibility to provide non-expired documentation of their lawful status in the United States. Examples of documentation to support lawful status include: • Permanent Resident Card (I-551) • Unexpired foreign passport stamped by the U.S. government indicating that the holder has been "Processed for I-551" • Permanent resident Re-entry Permit (I-327) • Arrival Departure Form I-94 with “Temporary I-551” stamp and holder’s photograph affixed • Travel Document issued to Permanent Residents (I-327) • Travel Document issued to Refugees (I-571) • Form I-94 stamped with one of the following statuses: Asylee, Parolee or Parole, Refugee, Asylum, HP-humanitarian parolee, PIP-public interest parolee, or Cuban-Haitian Entrant

The worker shall identify, in HE+ System Notes, the document witnessed which verified the individual’s lawful status in the United States. If the individual has an immigration status or verification document that is not identified above, the worker shall contact the HE+ Help Desk for guidance. Eligibility as an eligible non-citizen must be documented annually on each application to ensure the applicant’s immigration status is current.

3.2.3 Social Security Number (SSN) An SSN is required for the case head and all persons in the household who have been issued a valid number by the Social Security Administration (SSA). A person who does not have an SSN, and is eligible to apply for one, must do so with the SSA. See the following sections for SSN exceptions.

WHEAP agencies shall assist applicants to apply for an SSN. The SSN application form and instructions for applying for a new SSN can be found online.

WHEAP benefits will not be paid if, within thirty (30) days from the date of application, the case head has not supplied SSNs for all eligible household members. A denial letter stating that all information was not provided will be generated after 30 days. The entire household is ineligible for HE+ benefits if any eligible member fails or refuses to provide or verify their SSN or does not provide proof of application for an SSN.

When an applicant cannot provide the SSN for a household member(s), the household member(s) shall not be entered into the HE+ System until the SSN has been provided. The application will be incomplete until the SSN has been provided and verified.

In the event of an emergency situation, please see Chapter 5, Section 5.2.2, or the HE+ Program Services Manual located on the Division website.

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Revised: August 2025 3.2.3.1 SSN Verification SSNs must be verified through the HE+ System. When entering an HE+ Application, the HE+ System will prompt a web call to MCI to verify each SSN listed on the application. Agencies shall notify each applicant that all SSNs will be verified with SSA. There is a disclaimer on the paper HE+ Application which serves as notification when the intake method is non-interactive. There is a disclaimer on the electronic HE+ System application that shall be read to each applicant when the intake method is interactive.

The HE+ System will check the SSN against the MCI database administered through the State of Wisconsin Department of Health Services. The MCI database contains verified demographic information obtained by several other state programs. If the SSN(s) can be verified with MCI, the HE+ System will indicate that the SSN(s) has been verified and the worker can proceed with the application.

In the event the SSN(s) cannot be verified with MCI, the HE+ System will automatically send the SSN(s) to the SSA for verification. Verification with SSA will take approximately three business days. The worker should complete all other sections of the application and submit it for benefits. The application will automatically be sent to the worker’s “SSN Sent to SSA” inbox.

The “SSN Sent to SSA” inbox will contain any SSN(s) not found in MCI and needing to be verified with SSA. This requires no user interaction but is an informational inbox for application management purposes. Any application containing an SSN(s) waiting for verification from SSA will remain in this mailbox until SSA has processed the submitted SSN(s), which takes approximately three business days. If the SSN(s) are verified by SSA, the HE+ System will automatically release the SSN(s) allowing the application to extract. If the SSN(s) are not verified by SSA, the SSN(s) will move to the “SSN Rejected by SSA” inbox.

The Division will monitor SSN verifications and any abuse of the verification system by WHEAP agency staff may result in termination of HE+ System access.

3.2.3.2 Rejected SSNs The “SSN Denied by SSA” inbox is populated when any SSN(s) sent to SSA are returned as invalid. This inbox does require user action. The worker must contact the applicant and check if the number and associated information was entered correctly. The worker should identify any discrepancies and update the information in the HE+ System and may have to refer the applicant to the local SSA office for further follow-up. If the new information does not match the MCI database, the HE+ System will again automatically send the information to SSA for verification; the application will move back to the “SSN Sent to SSA” inbox. In rare circumstances, an SSN override may be needed. Workers shall check the "SSN Denied by SSA" mailbox on a regular basis to ensure all applications with a rejected SSN are being addressed in a timely manner.

NOTE: Do not disclose any information returned from MCI or SSA to the applicant. Only ask the questions to determine whether the information originally entered is correct.

In circumstances where the application is submitted and is waiting in the “SSN Denied by SSA” inbox beyond 30 days, the HE+ System will automatically allow for a fourteen (14) day extension

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37 Revised: August 2025 for purposes of SSN verification only. All other elements of the application must be complete, and the application must be in “Submitted” status for the application to not be denied as incomplete. An application will be prevented from denying as incomplete if it is waiting in the “SSN Sent to SSA” inbox, provided that all other aspects of the application are complete, and it is submitted. 3.2.3.3 SSN Exceptions If the household member meets one of the following exceptions for not having an SSN, indicate the reason there is no SSN on the household member record and include the proper documentation in HE+ System Notes.

3.2.3.3.1 Infants Infants (newborns) less than 60 days old where an SSN has not yet been issued may be processed without a valid SSN if the applicant has applied for an SSN for the infant.

3.2.3.3.2 Religiously Exempt from Social Security Applicants who are exempt from being assigned SSNs due to a religious conviction must provide the Individual Taxpayer Identification Number (ITIN) assigned by the Internal Revenue Service (IRS). Do not enter the ITIN into the HE+ System as the SSN. An HE+ System Note, including the ITIN, must be added to the HE+ System. Selection of the “Religiously Exempt” exception requires Division approval. Workers shall select “Send to SSN Override” from the Action Ribbon of the associated household member’s PID. Workers shall not use religiously exempt status as a place holder while waiting for SSN verification.

Religiously exempt individuals are those who are exempt from Social Security and Medicare taxes because they are a member of and follow the teachings of a religious group as defined by the IRS in the instructions for Form 4029 Application for Exemption from Social Security and Medicare Taxes and Waiver of Benefits. Parents who choose not to obtain SSN(s) for their children and are not a member of these religious groups do not meet the religiously exempt criteria. Their application will be incomplete if they do not provide SSN(s) for their children.

3.2.3.3.3 Ineligible Non-citizens Ineligible non-citizens without an SSN shall not be listed as a case head. IRS-assigned ITINs should never be entered in the HE+ System as SSNs for ineligible non-citizens. See Section 3.2.2.4.

3.2.3.3.4 Household Members Over 60 Days Old Division approval must be obtained prior to proceeding with any U.S. citizen over 60 days old if an SSN has not yet been issued or there are extenuating circumstances where the SSN cannot be verified. There must be a valid reason for the delay in obtaining an SSN and proof that an SSN was applied for. Documentation provided regarding the SSN application shall be uploaded to the application as “Other WHEAP Documents.” The Division will approve an exception on a one-time basis. The situation must be fully documented in the HE+ System “Household Member Notes” when the SSN override is requested. A valid SSN will be required on the next application. The Division adds notes regarding the SSN Exception request, showing the approval or denial. Requests for SSN exceptions shall be sent to the Division via the “SSN Pending Override” inbox when the worker selects “Send to SSN Override” from the Action Ribbon of the household

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Revised: August 2025 member’s PID. The required notes for this action appear as a household member note. Submitted applications are “on hold” until the SSN override is reviewed and approved or denied by the Division.

3.2.3.4 SSN Overrides The SSN Override function in the HE+ System may only be used in extenuating circumstances when an SSN has been rejected by MCI. Any SSN override request must include a System Household Member Note with the reason for the override request. To help the Division assess the override request, include what was done to verify the information entered, and if applicable, any important details for possible reasons the SSN was rejected. The Division must approve these overrides and will consider each on a case-by-case basis. Division staff may contact the worker via System Household Member Notes for more information pertaining to the override request.

SSN exception reasons “Other” and “Religiously Exempt from Social Security” require Division preapproval via the “SSN Pending Override” inbox when the worker selects “Send to SSN Override” from the Action Ribbon of the household member’s PID. See Section 3.2.3.3.4 regarding documentation needed for SSN exceptions.

3.2.3.5 Change SSN Request Simple Change SSN: In the event that a case head or any household member in the HE+ System has an SSN entered in the HE+ System that is later found to have been incorrectly entered, a Change SSN request must be completed. A Change SSN request can be made via the change SSN function found on the Action Ribbon when viewing Person Summary details from the PID containing the incorrect SSN record. This request will be sent to the Division through the HE+ System to complete the change SSN request. This will move or merge the records from the incorrect SSN to the correct SSN.

If an incorrect SSN has been entered for a case head on an unextracted application, the unextracted application must be deleted and entered using the correct SSN/PID. If there is application history under the incorrect PID for the person with the incorrect SSN, then a “Request Change SSN” should be requested before the application is entered into the HE+ System. Once the SSN has been corrected, the application should be entered under the correct SSN. An HE+ System Note should be added that the application was first entered with the wrong SSN. This System Note should include the PID under which the application was originally entered.

Complex Change SSN: For other cases where only select records from a history need to be transferred to a different SSN/PID record or SSNs have been transposed between household members, please contact the HE+ Help Desk for assistance in completing these requests.

3.2.4 Student Status and WHEAP Eligibility If the case head is age 25 or older on the date of the application, the case head’s student status does not need to be verified.

Student status must be determined for case heads enrolled in institutions of higher education when the case head is under age 25. A case head enrolled in school half-time or more will be eligible for an energy assistance benefit only if WHEAP financial criteria, WHEAP non-financial criteria, and at

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39 Revised: August 2025 least one of the following WHEAP student status criteria is met: 1. The case head is physically or mentally disabled (disability must be verified, i.e., Veterans or Social Security Disability benefits), and the verification of disability is entered in HE+ System Notes 2. The case head is receiving W-2/TANF cash benefits 3. The case head or their spouse (if married) is financially responsible for a child 18 years old or younger who is living in the same household 4. The case head lives with a spouse who is not a student 5. The case head currently works an average of 20 or more hours per week for at least minimum wage 6. The case head is a full-time student receiving extended unemployment compensation benefits under the Trade Adjustment Assistance (TAA), sometimes referred to under the North American Free Trade Act (NAFTA), provisions designed to enable the case head to be a full-time student. The TAA benefit award is limited to one year.

WHEAP case heads under 25 years old are considered students if they are enrolled, on a half-time to full-time status, in an institution of higher education that requires a high school diploma or an equivalency certificate (i.e., universities, colleges, technical, trade, vocational schools, and schools for the physical or mentally disabled). Determination of a student’s status as a full-time, half-time, or part-time student is based on the institution’s assessment/policy. Questions about status that cannot be resolved with the institution should be addressed to the HE+ Help Desk.

Student status expires at midnight on the last day of the applicant’s final semester as per the institution of higher education’s established semester end date.

NOTE: A minor case head is not considered a student because they are not in post-secondary education.

3.2.4.1 In Between Enrollments Individuals who have graduated from high school and have not yet enrolled in post-secondary education are treated as adult members of a household (unless they are under 18 years of age) until they begin their education. This may affect a few early applications, taken in August or September, as the individual’s status is determined on the date of the application. It may also affect individuals who have had non-traditional high school graduation dates. If there is such an individual in the household, count the income of the adult (age 18 and older) for the month prior to the date of the application.

3.2.4.2 High School Enrollees A high school student may be considered a case head only if over 18, or if they are an emancipated minor (see Section 3.2.1). If the student is enrolled in a regular high school program leading to a diploma, the student status is not considered in determining eligibility. If the student is enrolled in a program leading to a General Education Diploma (GED) at a technical school or other institution, that program does not qualify as post-secondary education and may not be used to qualify an applicant for student status.

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Revised: August 2025 3.2.5 Energy Burden To be eligible for energy assistance, the household must have a heat/electric burden on the date of the application. Table 3.2: Energy Burden (see Section 3.2.5.2), provides examples of situations and determinations of energy burden.

In addition to having an electric burden, there must be a relationship with a utility participating in the State Public Benefits program for an applicant to be eligible for non-heating (PB) electric assistance.

Responsibility for energy, heat and/or electricity, in the household can be demonstrated in several ways including, but not limited to: 1. Having an account with the energy supplier and directly paying the bills 2. Having the cost of the energy (heat and/or electricity) included in the rent 3. Making separate payments to the landlord for the energy supplied (heat and/or electricity) 4. Gathering or cutting wood used for heating, or purchasing wood from a non-registered supplier

When the account is not current because the vendor has closed the account (for lack of payment or other reasons), the relationship between the vendor and the applicant needs to be examined. • If the applicant has not moved and a different vendor will not be serving the household, the agency should work with the vendor and the applicant to get an account re-established. • If the applicant has moved, or has identified a new vendor to provide service, the agency should work with the new vendor and the applicant to get an active account established.

3.2.5.1 No Energy Burden Households The following do not satisfy the energy burden requirement: 1. Applicants who have no responsibility for heating/non-heating electric because the costs are being paid in full directly to the fuel supplier (or landlord, if heat/electric is included in rent) by a government program. 2. Applicants residing in government-assisted housing (subsidized housing) or receiving rental assistance and heat and/or electric is included in their rent. NOTE: Residents of housing units receiving Low Income Housing Tax Credit (LIHTC), also known as “Section 42,” with heat and/or electric included in their rent do have an energy burden as they are not considered residents of government-assisted housing. 3. Renters who pay neither rent nor heating/electric costs because of an in-kind rental agreement. Renters who do not pay toward heating/electric costs when there is a shared meter and they do not pay any energy costs to anyone. 4. Tenants of group homes where the costs of care are paid by a local, state, or federal agency or charitable organization. This includes, but is not limited to, halfway houses or CBRFs.

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41 Revised: August 2025 5. Residents of medical or correctional institutions including nursing homes, assisted living facilities, government institutions, or jail when the applicant is not responsible for paying their heat and/or electric costs. 6. Tenants of facilities that pay a portion of their maintenance or care have no energy burden unless they pay their food and shelter costs.

3.2.5.2 Energy Burden Table The following table presents a variety of examples of energy burden questions and indicates (middle column) if the example satisfies the energy burden requirement. The final column indicates the method by which payment will be made, if appropriate.

Table 3.2 Energy Burden Applicant Heat/Electric Situation Have An Energy Burden Type Of Payment Pay an electric/heating vendor directly for use. Yes Designated vendor will receive a payment. Heat/electric is included in rent. This includes tenants in Section 42 (LIHTC) housing units. Yes Applicant will receive a single party check based on a proxy amount for the heat/electric costs. Heat/electric is paid to the landlord or trailer park owner. Yes Applicant will receive a single party check based on a proxy amount for the heat/electric costs. Applicant gets electricity through an extension cord from a neighboring residence (from a house to a mobile home for example). No Applicant is not eligible for an electric benefit and will not receive a payment for electricity. Applicant has a separate meter/account for his or her residence - someone else pays the bill. Yes Designated vendor will receive a payment that may be based on actual fuel costs for the residence. Applicant has the account name listed in a non-household member's name. Yes Designated vendor will receive a payment that may be based on actual fuel costs for the residence.

If the account name is under a deceased spouse, protective payee, or other and is a direct pay account, actual energy costs may be used. Applicant rents. Heat/electric are not included in rent. Account is in the landlord’s name. Tenant directly pays energy provider. Yes Designated vendor will receive a payment that can be based on actual fuel costs for the residence. Applicant has a shared meter/account with another residence, does not have heat/electric included in their rent, nor do they pay any heat/electric costs to anyone. No Applicant is not eligible for a benefit and will not receive a payment.

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Revised: August 2025 Applicant Heat/Electric Situation Have An Energy Burden Type Of Payment Applicant lives in a residence with a master meter for heat/electric and the account is in the applicant’s name. Yes Applicant has a relationship with a vendor; designated vendor will receive a payment based on a proxy amount for the master metered fuel(s). Agricultural, business, or industrial activities on the same meter/account as the applicant's residence. Yes Designated vendor will receive a payment based on a proxy amount for the heat/electric cost. Applicant has a shared meter/account with another tenant, and applicant pays the other tenant an amount for the heat/electric bill. Yes Applicant will receive a single party check based on a proxy amount for the heat/electric costs. Applicant heats with wood, the wood supplier is not a registered vendor, or applicant cuts his or her own wood. Yes Applicant will receive a single party check for heat benefit based on a proxy amount for the heat costs. Applicant receives rental assistance (Section 8 or other similar government-assisted housing) and heat/electric is included in their rent. Section 42 (LIHTC) housing units are not considered government-assisted housing. No Applicant is not eligible for a benefit and will not receive a payment.

3.2.6 Counting Household Members Enter all persons living in the household on the date of the application unless specifically excluded (see Section 3.2.6.4). All persons in the economic unit are considered members of the household if they are living in the household on the date of application. Household members who are temporarily out of the household on the date of the application for reasons such as a vacation or business trip are still considered part of the economic unit and are counted on the HE+ Application. In addition, those working out of town but not maintaining a separate permanent residence are also considered part of the economic unit. A lease may or may not list all those satisfying the WHEAP definition of a counted household member.

If the household composition changed during the prior month test period, consider only the persons living in the household on the date of application. Do not count persons who may have lived in the household during a portion of the test period but are no longer in the household on the application date. If the household member resides in more than one residence, the local WHEAP agency must indicate in HE+ System Notes on what basis they determined the primary residence.

3.2.6.1 Counting Children Enter children as members of the household where they reside. In custody cases where a child(ren) lives in more than one location based on shared physical placement, count the child(ren) in the household where they reside more than 50% of the year. If the applicant states that the child(ren) are part of a true 50%/50% physical placement situation, the child(ren) can be recorded on the application of both parties. If a minor has unearned income, the unearned income shall be counted in the household where the income is being received.

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43 Revised: August 2025 The worker shall indicate in HE+ System Notes what the applicant stated about the child(ren)’s current living situation and how to include or exclude the child(ren) as a current household member was determined.

To verify the current living situation of a child(ren), consider any of the following information: court order(s), information from Income Maintenance cases or other economic support records, school registration records or contact information. Please contact the HE+ Help Desk if assistance is needed in determining if the child(ren) should or should not be included.

NOTE: 50% legal custody is not the same as 50% physical placement. The parent must have at least 50% physical placement in order to include the child(ren) on the application as an eligible household member.

3.2.6.2 Non-citizen Household Members 1. Enter eligible non-citizens as household members. See Section 3.2.2.4. 2. Enter ineligible non-citizens as household members and indicate their status as ineligible non-citizen. All policy related to counting income applies to ineligible non-citizens. Count all applicable income for ineligible non-citizen household members.

3.2.6.3 Medical Attendants or Caregivers for Individuals with a Disability A medical attendant or caregiver is a person who cares for a household member to allow the household member to remain in their home, instead of a nursing home or institution. Money paid to the caregiver in this situation that allows an individual to remain in their home is not counted as income as long as the caregiver resides in the same dwelling as the disabled person. If the caregiver applies for energy assistance and doesn’t reside with the disabled individual, then the caregiver income is counted on the caretaker’s WHEAP application. If the dwelling is an Adult Family Home, see Section 3.3.2, #7 for more information. A caregiver is not counted as a household member if they maintain a separate household as their primary residence and do not live with the household member they are caring for. If the medical attendant or caregiver lives in the household of the person they are caring for and it is their primary residence, then they are counted as a household member.

3.2.6.4 Household Members Not Included on Application The following is a list of the persons who should NOT be included as household members: 1. A temporary household member. Do not count the person or their income. 2. A foreign exchange student from another country attending school on an exchange program. 3. College students, unless they live in the home full-time and are commuting to school. If the student has any living facilities other than the home, they may not be counted in the household, for example: have a dorm room, rent a room or an apartment. Individuals who have started their post-secondary education may not be counted as household members during semester breaks or over the summer (between terms) unless they are commuting students.

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Revised: August 2025 4. Foster children who are placed for care by a court order. Contact the HE+ Help Desk for further guidance for situations with long term (over one (1) year) placement of foster children. 5. A household member who has been called to active duty in the military and is to be out of the household for at least 60 days. The base income of this individual should not be counted. Any household support provided to maintain the household (i.e., housing allowances, allotments sent directly to the household for support) is counted as income for the household.

3.3 Financial Eligibility 3.3.1 General The WHEAP income test is based on 60% of the SMI level. If the household's gross income is less than or equal to the income limit for its size, the household passes the income test. If the gross income exceeds the limit, the household is not eligible unless categorical eligibility criteria are met. The income guidelines for different household sizes can be found on the Division website. 1. Assets

The HE+ Program does not have a vehicle or asset limit test for eligibility. While Regular WHEAP Benefits lack an asset test, assets may be considered in deciding Crisis Assistance benefits or HE+ Program Services, including assets of the landlord, if applicable to the situation. The proceeds of the sale of an asset are generally not counted as income. If the sale proceeds: a. Include capital gains realized from the asset, the capital gains are not counted as income. b. Involve a series of payments, any interest included in the payments needs to be counted as income. One common example is a land contract sale of real estate; the land contract should contain a description of the payments showing the principal and interest amounts (often this is in a chart or table). 2. Categorical Eligibility

Categorical eligibility status allows a household to pass the income test if they are above the 60% SMI level. For a household to be determined as categorically eligible, every household member must be a recipient of Wisconsin Works (W-2)/TANF, FoodShare, or Supplemental Security Income (SSI) for the month prior to the date of application. W-2 is considered a categorical eligibility criterion only if there is a “cash benefit.” a. W-2/TANF: If the household is over income for WHEAP but is determined to be categorically eligible because the household is receiving W-2, the agency must verify that all household members are a part of the assistance group and document, in HE+ System Notes, how this was verified. b. FS: If the household is over income for WHEAP but is determined to be categorically eligible because the household is receiving FoodShare, the agency must verify that all household members were receiving FoodShare in the month prior to the date of application and document in HE+ System Notes how this was verified. System Notes should specifically indicate which household members and months FoodShare was received.

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45 Revised: August 2025 c. SSI: The SSI category includes the Caretaker Supplement Income (Caretaker Supplement is abbreviated as CTS or C-Sup). d. If some, but not all, of the household members (including ineligible non-citizens) are recipients of W-2/TANF, FoodShare, or SSI for the prior month test period, the household is not categorically eligible. e. If the household member(s) is a recipient of W-2/TANF, FoodShare, or SSI and does not have a first-of-the-month effective date for receiving program benefits, do not consider him/her categorically eligible. The recipient must receive the benefits for the entire month. NOTE: Receipt of Social Security Retirement benefits or Social Security Disability Insurance (SSDI) cannot be used to establish categorical eligibility.

3.3.2 Counting Income Determine the income amounts consistent with the test period and the type of income. 1. Test Period

The test period is the time frame during which income is counted to determine eligibility. The time frame varies by income type. For most individuals with an income source, the test period is based on gross income received during the prior month. The test period may also be based on gross income received during the previous tax year. WHEAP agencies may accept a W-2 form issued by the current employer as verification. Agencies shall review the applicant’s income and work history to determine if a W-2 is the best option to use to verify household income. If a W-2 is used, apply the amount reported in Box 5, divide by 12, and enter for the prior month test period. When households receive an extra check from wage income in the test period, workers shall ignore the first check received. See Section 3.3.9, Table 3.6: Ignored Income Types.

The test period can also be based on gross income received during the 12 months prior to the date of the application, or the previous tax year for income types such as interest, dividends, annuity, tribal per capita payments, seasonal worker income, and self- employment income.

If the household’s prior month income exceeds the WHEAP eligibility limit and the household’s financial circumstances have recently changed (due to divorce, loss of a job, accident, etc.), agencies may use the present month as the income test period. The prior month income shall be documented with an HE+ System Note and with verification documents uploaded to the application. If the test period is the present month, agencies shall estimate the income based on information provided by the household using the Present Month Income Attestation Form. 2. General Guideline

Count all gross income received by all household members on the date of application for the appropriate test period. For self-employment income and seasonal wages, see the specific directions in the following sections.

Do not count or enter earned income for minors under the age of 18 (or full-time high school students) at the time of the application. If a minor has unearned income (SS, SSDI,

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Revised: August 2025 SSI), the unearned income shall be counted in the household where the income is being received. 3. Interest and Dividends

Count interest and dividends as gross amounts received/earned in the 12 months prior to application, or during the previous tax year. Interest payments from land contract sales are recorded as land contract payments and can be recorded monthly if the amortization (payments) schedule is available (if an amortization schedule is not available it may be necessary to use amounts based on prior year’s taxes).

Ignore this income only if the interest and dividends combined is less than $120 per year ($10/month). Ignore interest and dividends if the household member does not have access to the funds, such as interest on IRAs and CDs. To the extent it can be identified, ignore the interest from asset account for applicants with a PASS plan (SSI Plan for Achieving Self Support).

Count the full 12 months and enter the monthly average amount for the prior month test period. Interest and dividends should be added together as one entry per household member. Document in the source field or in a System Note each source of the interest and dividends reported.

For verification, do not accept statements that show only the interest earned for the prior month test period. The 1099 form issued by the payer or Schedule B of the 1040 tax return are acceptable forms of verification.

Interest income is reported on line 2a and 2b of the 1040 tax return. The amounts on line 2a (tax exempt interest) and 2b (taxable interest) should be added together to calculate the interest income.

Dividend income is separated as Qualified Dividends on line 3a and Ordinary Dividends on line 3b of the 1040 tax return. Use line 3b (Ordinary Dividends) only as this represents the total dividends reported which includes the Qualified Dividends. 4. Some residents of buildings with income-based requirements for occupancy live in a building where their energy costs (both heat and electric) are included in their rent. Such residents are not eligible for WHEAP benefits because they have no energy burden. Applications can be taken from the tenants of such buildings to determine eligibility for Weatherization. The local WHEAP agency will follow processes below in determining eligibility: a. Collect copies of waivers signed by the tenants allowing the property manager (landlord, housing authority) to release income information to the local WHEAP agency. b. Collect household information (SSN for each resident in the household, number of rooms, income, and any other information needed to complete the HE+ Application) from the property manager. c. Obtain from the property manager an assurance that the case head for each application is who they say they are.

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47 Revised: August 2025 d. Check the box on the fuel question indicating, “Do not pay.” e. Collect a signed and dated Certification Page from each applicant/resident. (For more guidance see Section 4.4.29) 5. Deductions from Income

Do not make deductions from gross income for employment-related expenses, childcare, medical expenses, or for any other reason not stated in this chapter. No deductions from gross income are allowed except as specifically identified in this chapter, or as part of the Income Deducted Table (Section 3.3.8).

Garnishments removed from income are not an allowable deduction from income. Take care to ensure the income counted is the total gross income amount for each pay period. 6. Managed care cases residing in an owner-occupied AFH (Adult Family Home) Residents living in an owner-occupied AFH are considered part of the economic unit. They should be listed as household members and the income they receive shall be recorded as part of the household income. Money paid to the caregiver as their “rent” should be ignored income. Money paid to the caregiver as part of their general care should be counted as wage income for the caregiver. Because these residents are part of the economic unit, this income shall not be calculated as self-employment income. Contact the HE+ Help Desk if there are questions on managed care income. 7. Pensions, Annuities, and Deferred Compensation (IRA, 401K, 503b, etc.) Pensions, Annuities, and Deferred Compensation are intended to provide income during retirement. They are different sources with different rules regarding when and how they are paid out. At any point that money is received from these sources as income, they are counted income. Situations in which withdrawals are made from any of these accounts ahead of retirement will determine if this income is considered counted income or ignored income. The point at which an IRA or Annuity is annualized or at the time the holder is required to make withdrawals, it is counted as income.

Reminder: Deductions for Medicare Part B, Part C, and Part D should be subtracted from the gross amount of Social Security Retirement benefits. In addition to subtracting this deduction from Social Security Retirement, this deduction should also be applied to those receiving federal pensions and Railroad Retirement who are not eligible for Medicare benefits because of these prior employments. No other medical deductions are allowed. See Section 3.3.9 under Medicare. a. Pensions are payments earned from employment and are usually paid on a monthly basis. Gross income should be counted. Some pensions can include deductions for various purposes and benefits can fluctuate from year to year. Retired Military Compensation should be recorded as Veterans benefits. b. Annuities that are paying out regular payments should be counted as income. If paid monthly, include this income in the test period. If payments are received quarterly or annually, annualize the income and divide by 12 to calculate the monthly income amount for the test period. c. Deferred Compensation is a retirement savings account. At the point the individual is receiving regular payments, they are counted as income. If payments are

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Revised: August 2025 received monthly, count the monthly income for the test period. If received quarterly or annually, annualize the income and divide by 12 to calculate the monthly income amount for the test period. d. Pension, Annuities, and Deferred Compensation payments are scheduled and paid on a regular basis. For pension or annuities paid on a monthly basis, enter the monthly gross benefit. For those paid on a quarterly and/or other basis, enter the average monthly amount. Often 1099 forms can be used for verification. Payments reported to be “rollover” on taxes are ignored but HE+ System Notes shall include how it was verified. e. Payments from trust funds that make regular payments to the beneficiary are counted as income. Trust fund income will be reported on K-1 and Schedule E Part III. Monthly verification is acceptable. f. Military retiree, survivor, or beneficiary compensation, and Veterans Affairs (VA) Disability Compensation should be recorded as Veterans benefits. g. For withdrawals: i. If the account owner is 73 or older or is younger than 73 but has inherited an IRA from someone who was older than 73, count all withdrawals from the account as income. Withdrawals are annualized by calculating all withdrawals within the year and dividing by 12 to arrive at a monthly income amount. ii. If the account owner is under 73 years of age and has not inherited an IRA from someone who was older than 73, count as income all withdrawals from an account that are regular payments. Withdrawals that are not regular and not required may be a reduction of assets and not included as income for an account holder under the age of 73.

3.3.3 Child Support 1. Received in the Household a. Count all child support payments received, regardless of source i. Count the actual money received even if it exceeds any court-ordered amount or comes from other programs or parties than the non-custodial parent. Exception: See lump sum payment. ii. Count the child support payments as income even if the child is not actually living in the house at the time of the application. iii. Regular, recurring payments received that are for the purpose of paying down arrears are counted as income. b. If a lump sum payment is made for arrears, including tax intercept income, only count the amount of the payment that applies to the test period. 2. Payments made by the Household a. Court ordered child support payments paid by a household member/applicant are deducted from total household income.

Regular recurring payments paid to pay down arrears are deducted from income.

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49 Revised: August 2025 Payments made by a household member/applicant for child support that are not part of a court order shall be ignored and may not be deducted from income. Payments for alimony or maintenance may not be deducted from income.

Payments, even if court ordered, intended to pay for outstanding bills (medical or otherwise, legal costs, or other non-custodial expenses) may not be ignored or deducted from income.

If a lump sum payment is made for arrears, including by tax intercept, only deduct the amount of the payment that applies to the test period. The worker must verify whether any part of the lump sum payment applied to the test period. 3. Child Support for Non-Resident Child a. If a household receives child support payments, but the child actually resides more than fifty percent (50%) of the time in some other household, do not count the child as a household member, but count money received (regardless of what the household does with the child support funds).

3.3.4 Spousal Impoverishment A spouse who is in a nursing home (institutionalized spouse) for more than 30 days may allocate some or all of their income to their spouse (community spouse). The Spousal Impoverishment provision ensures that the community spouse has income to meet household expenses. Money not allocated to the community spouse must be used to pay nursing home costs and is not available to the community spouse. Count the income received as a result of Spousal Impoverishment income allocation provisions of Wis. Admin. Code HSSS §103.07(1)(9B)2 as direct income for the community spouse. Do not count the personal needs allocation that the institutionalized spouse is entitled to receive (typically a minimum of $45).

3.3.5 Self-Employment Income Self-employment income (including self-employment and farm income) is determined by using a 12-month test period and entering an averaged, annualized amount for the prior month test period. If the business ended during the same calendar year and prior to the test period, this self- employment income is not entered on the application. Document in HE+ System Notes the business operation end date to verify the status of the self-employment income. Other types of income for the individual or household are entered separately on the application and do not affect the self-employment income entries in the HE+ System.

When a household has more than one type of self-employment income, the losses of one shall be used to offset the profits of the other based only on the income reported on the income taxes. The offset does not have to be applied to only the same household member but can be applied to any other household member’s self-employment income. For purposes of calculating income on the HE+ Application, rental and royalty income (entered in the HE+ System using “Rental Income” (R) income type) shall be included in the offset of losses and profits of self-employment income. When there is a realized loss in self-employment income, enter self-employment income as a separate income source and $0 as the amount for that source on the HE+ Application.

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Revised: August 2025 Self-employment income losses may not be offset by wages, interest income, government program benefits, self-employment income reported on the S-GIRF, or income reported on a 1099 (independent contractor).

NOTE: For the purposes of calculating income, ownership and management of rental property and royalty income are considered self-employment income and this income is entered in the HE+ System as “Rental Income.”

Net operating loss (NOL) reported on line 8a of Schedule 1 shall be ignored and not used to offset any profit of self-employment income reported on the Schedule 1. See definitions in Chapter 1 for more information on NOL.

3.3.5.1 Verification of Income − Self-Employment Income The worker shall ask all applicants with self-employment income in the household whether taxes were filed for the prior calendar year. If taxes were filed, the tax return must be provided by the applicant. Request the federal 1040 form and Schedule 1. Use a copy prepared by a professional tax accountant, if available.

If applicant has self-employment income ask the following question: • Do you have more than one source of self-employment income?

If applicant has rental income ask the following question: • Is all rental property included on tax forms?

If applicant has farm income ask the following question: • Is all farm income included on tax forms?

If yes to any questions above, request corresponding schedules.

Use the self-employment income reported on the IRS 1040 tax forms for the most recent tax year. If the prior calendar year taxes are not available by the tax filing deadline, document in HE+ System Notes why prior calendar year taxes are not available. Divide the total net annual income from the Schedule 1 by 12 to obtain the average monthly income amount; if in business for less than the full calendar year, divide the total net annual income by the number of months the business was in operation. For example, if the business started July 1 of the previous year, take the net annual income and divide it by six (6). If a business generated income for only a few months of the previous year, but was in existence for the whole year, divide the net annual income by 12 to get the average monthly income. (Seasonal businesses would be an example of this situation.) Income should only be entered for the months of the test period if the business was still in operation during that time.

When the applicant did not file taxes or did not file self-employment on their taxes, instruct them to complete an S-GIRF as found on the Division website. See Section 3.3.5.2. A copy of the S-GIRF and/or tax records shall be retained in the HE+ System as a document upload. Rental income must be verified by tax records for HE+ Program Services. If rental income is not verified by income taxes for the homeowner or dwelling owner, the homeowner, including the rental unit, may not be

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51 Revised: August 2025 eligible for a HE+ Program Services referral. Please contact the HE+ Help Desk if the homeowner or dwelling owner does not file taxes.

3.3.5.2 Use of Self-Generated Income Report Forms An S-GIRF may be used to verify self-employment income when an applicant states they did not file taxes in the most recent year or did not file self-employment on their taxes. In such a case, the S-GIRF must cover the previous 12 months to the date of application. Sum the total of the gross income provided on the S-GIRF and divide by 12 to calculate monthly income and enter that amount for the prior month test period. A separate S-GIRF shall be used and entered as a separate entry in the HE+ System for each source of self-employment income. Completed S- GIRFs shall be retained with the application as a document upload in the HE+ System.

The S-GIRF can be found on the Division website via Provider Resources │ Energy │ Energy Assistance.

NOTE: No income deductions are allowed when reporting self-generated income on an S-GIRF. Deductions or expenses related to self-generated income shall not be factored into the amounts counted as income unless the applicant provided the complete tax return from the prior year.

The S-GIRF shall be used to report self-generated income if: • Money is received for self-generated income without an organized self-employment business and/or self-employment is not filed on the applicant’s taxes. Examples include odd jobs, childcare, cleaning, donating plasma, etc. Cash jobs are considered self- generated income when working for employer(s). When receiving cash from an employer(s), report as wages using the Wage Attestation form for the test period. • The source of income, business or farm was not in operation during the previous year and IRS tax forms are not available.

Example: The business or income started in June and the applicant is applying in November. The business operated for five months (June through October.) Divide total income by five (5) to arrive at the amount per month and enter that amount as self- generated income for the prior month test period.

Example: The business or income started in February and the applicant is applying in April. The business or odd job income operated for two months (February and March). Divide total income by two (2) to arrive at the monthly amount for March. • An independent contractor who receives a 1099-NEC is self-employed and is not considered an employee. If confirmed the applicant is an independent contractor, workers shall utilize the 1099 if income taxes were not filed for verification of income. Divide total income by the number of months worked and enter that amount as self-employment income.

Example: The applicant works for Uber and is provided with a 1099-NEC and worked for Uber for the full year. Divide total income by twelve (12) to arrive at the monthly amount. • Chapter 7 bankruptcy has been filed since tax forms were last completed.

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Revised: August 2025 NOTE: The last day of work would be the day that the bankruptcy papers were filed. Do not use last year's tax form; use the S-GIRF to calculate income.

NOTE: A person who files bankruptcy under Chapter 11 of the federal bankruptcy laws and remains self-employed is not considered to have a significant change. Base income on last year's tax return and any approved bankruptcy reorganization plan.

3.3.5.3 Self-Employment Income and Annual Fuel Use When self-employment income is in, or based in, the home (or other areas on the property which have their usage recorded on one meter), the actual fuel cost should be entered but is not used to calculate the benefit. The applicant will receive a benefit based on a proxy amount for heat/electric costs when “Yes” is selected for business use on the account in the Energy Fuels section of the Application. See Section 4.4.28.11 for tests to determine if business use should be marked “Yes” on the account.

3.3.5.4 Document Upload Document upload includes all income types. Before an application can be submitted, the HE+ System requires document uploads for all income entries and a completed ZIF for all zero-income applications. Any documentation that an applicant submits must be uploaded to the application in the HE+ System even if the application is incomplete or will deny for another reason. Once an application is extracted, any additional document uploads for the application must be made via the “Other WHEAP Documents” upload repository. Workers shall verify all document uploads were successful and can be viewed and/or are accessible based on the document type.

Redact the following information from all documents uploaded into the HE+ System: • SSNs on all forms and leaving the last four digits of the SSNs • Tax preparer ID • Bank routing information • Employer Identification Number (EIN, TIN, Shareholder’s identifying number)

Document uploads are completed and viewed in the HE+ System via the document upload slider, which is indicated by the paperclip icon on the left-hand side of the application view window.

If the form of income verification is obtained from a policy-allowed electronic third-party source, a legible screen print from the third-party source is an allowable upload. Please see Appendix B for more guidance regarding allowable forms of income verification.

Self-employment income: All self-employment income verification must be retained as part of the application by conducting a document upload for each of the following income types: • Self-employment (SE) income • Rental (R) income

A document upload is required on each SE income and/or R income record entered on the application.

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53 Revised: August 2025 • When tax documents are provided as income verification for self-employment, the federal 1040 form and the Schedule 1 (Form 1040) must be included in the upload. State returns and other federal forms not related to the self-employment income are not required. • Multiple uploads can be attached to one income type. • Avoid using the application number as part of the file name because the HE+ System adds the application number as the first part of the document name during the document upload.

Zero income: When the household is identified as a zero-income household, the required ZIFs are to be uploaded to the application. When ZIFs are required, the form(s) are retained by document upload. If there are multiple adults on the application, a separate ZIF is required for each adult. Agencies may upload separate ZIFs or scan all ZIFs and upload as one document. A ZIF may not be required if ignored income has been verified through a third-party source. The verified income may be uploaded in lieu of the ZIF. Application System Notes should be clear why a ZIF was not completed.

Naming the document: • Identify the file with the case head and/or household member name to ensure the correct file is uploaded to the associated application. • Avoid using the application number as part of the file name because the HE+ System adds the application number as the first part of the document name during the document upload.

3.3.6 Seasonal Workers’ Income Seasonal workers are individuals whose primary employment/source of income is normally earned in fewer than 12 months per year. Seasonal workers may be paid on a 12-month basis but earn their income in fewer than 12 months. If the seasonal employment has not been in effect for 12 months, calculate the seasonal income from the start date to the end of the prior month (of the application date) and divide by the number of months this covers. Contact the HE+ Help Desk if you are unable to utilize W-2 to verify the seasonal income.

If an individual is determined to be a seasonal worker, indicate in System Notes what information was used to make this determination.

Individuals who have regular (year-round) employment or source of monthly income and hold second jobs in seasonal businesses are not seasonal workers for the purpose of calculating income. An individual who holds a seasonal job but is not determined to be a seasonal worker because they have a regular source of income should have each income calculated per the test period.

A seasonal worker may have more than one job or source of income. If a household member’s primary source of income is determined to be seasonal, divide by 12. If the seasonal employment has not been in effect for 12 months, calculate the seasonal income from the start date to the end of the prior month (of the application date) and divide by the number of months this covers. All other income types should be counted as per policy for that income type.

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55 Revised: August 2025 Income Counted Types HE+ System Code Government Relief or Disaster Aid Funding received from federal government assistance. This includes the match grant money/resettlement funds a refugee receives upon arrival in the U.S.

NOTE: Refugee Cash Assistance (RCA) is reported as General Relief income. (GV) Land Contract Count only the interest portion of the payments as income. (LC) Land Rent Income from land used for, including but not limited to, cash crop fields or pastured livestock. Ignore annual amount earned up to $120. (R) Lump Sum Payments Counted Lump sum payments received from employers for compensatory time, unused sick leave, and unused vacation time are counted and should be prorated over the number of months covered. (W) Other Use only when an income type does not exist and indicate in the Source Field the type of other income. (O) Other Direct Payments (Regular and Scheduled) Regular and scheduled payments of any source of income (received monthly, quarterly, annually, or on any regular schedule) that is not classified as ignored income. • Respite Care if received as salary • Payments for shelter costs or normal living expenses (rent, clothing, food eaten at home) • Regular payments from a trust fund

(W) (W)

(P) Pensions, Annuities, and Deferred Compensation (IRA, 401k, 503b, etc.) These payments are scheduled and paid on a regular basis. For pension or annuities paid on a monthly basis, enter the monthly gross benefit. For those paid on a quarterly and/or other basis, enter the average monthly amount. See Section 3.3.2 for additional information. (P) Rental/Royalty Income Enter income in the HE+ System using (R) income type. See Section 3.3.5 for more information on counting self-employment income.

NOTE: If rental income is paid to other household members of the economic unit, the rental income received is ignored. This is ignored because it is considered a distribution of household expenses. (R) Self-Employment Income This includes farm income. See Section 3.3.5 for more information on SE income. (SE)

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57 Revised: August 2025 Income Counted Types HE+ System Code Training Allowances Vocational and rehabilitative program money recognized by federal, state, or local governments. Example: • Wisconsin Employment Opportunities Program (WEOP) • Workforce Innovation and Opportunity Act (WIOA – formerly WIA)

NOTE: Related reimbursements and payments made directly to service providers for childcare, tuition, and fees may be ignored except for any amount in excess of actual expenses, which must be counted as income. See also Reimbursements in the Ignored Income Table, Section 3.3.9. (W) Tribal Per Capita

Tribal per capita gross amounts received in the 12 months prior to application, or during the previous tax year, less the first $2,000 received by the applicant in the same 12 months or the same tax year, then divide by 12 to get the monthly amount. If the total gross amount is $2,000 or less, treat the entire amount as ignored income. (TR) Veterans Benefits Veterans’ benefits are counted income. These may be identified by the VA as the following: • VA Compensation: for disability during war activity • VA Pension (do not list as pension income): for disability that was acquired outside of war activity • Retired Military Compensation: regular retirement • Dependency and Indemnity Compensation (DIC) (V) Wages, Salaries, Commissions, and Tips Count all gross income received in the prior month test period (based on payment or check date) by all adults 18 and older living in the household (see Section 3.3.9 for exceptions). • Count commissions in the test period they were received. • Seasonal workers: calculate earnings by dividing the person's gross income from W-2 statements or the 1099 by 12. Report the monthly income for the prior month test period. (W) Worker’s Compensation Worker’s compensation payments are counted income. (WK) Zero Income Cases When households report zero income, an in-person or phone application is required. See Section 4.4.27.2 for self-certification requirements of zero income households. N/A

3.3.8 Income Deducted Table The following table provides a listing of the income deducted types including a definition/description.

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Revised: August 2025 Table 3.5: Deducted Income Types

3.3.9 Ignored Income Table The following table provides a listing of the income deducted types including a definition/description.

Table 3.6: Ignored Income Types Ignored Income Types Adoption Assistance Social Security Act Title IV-E Fund. Provides monthly payment to adoptive parents to assist with the care of a special needs child. Count the child in the household. Assets • Any personal asset sold in the prior month test period; see Section 3.3.1 (1). • Withdrawals from the principal of interest/dividend earning accounts as savings accounts, stocks, certificate of deposits (CD), U.S. Treasury Bonds, etc. • Lump sum withdrawals from an IRA account before the account owner is 73 years old or the account owner is under 73 but has inherited an IRA from someone over 73 are not counted as income. • Capital gains

NOTE: All lump sums for someone under 73 years of age are ignored when it is an asset.

NOTE: Remember to check for interest, which is counted as income if greater than or equal to $120 per year. Bonus Any received bonuses and profit sharing. COVID-related income Temporary COVID-related income shall be ignored, including the following: • Bonuses or hazard pay from any employers including tribal governments • Increased benefits to tribal members Dividends/Interest If the annual combined total earned is less than $120, ignore the income. Income Deducted Types Child Support Paid Enter the child support paid in the test period and the HE+ System will subtract the child support paid from the income calculation. See Section 3.3.3. Medicare Part B, Part C, and Part D Premiums • The Medicare Part B, Part C, and Part D premiums shall be deducted when entering Social Security Retirement income. • Medical insurance premiums shall be deducted from the retirement pay of those receiving federal retirement or Railroad Retirement benefits, up to an amount equal to the standard Medicare Part B, Part C, and Part D premium.

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59 Revised: August 2025 Ignored Income Types Earned Income for Minors (under 18) If the household member(s) is under 18, ignore earned income (including wages and unemployment compensation). Earned Income for High School Students 18 and Older If the household member(s) is age 18 or older and is a full or part-time high school student, ignore earned income (including wages and unemployment compensation). Flex Dollars Ignore flex dollars used for health insurance premiums when the dollars would not otherwise be available to the applicant. General Relief General Relief from Interim Assistance (IA) programs for individuals that have applied for SSI is ignored income, as this assistance is repaid from the individual’s lump sum eligibility payment. Government Payments and Program Participation Income • Payments or allowances made under any federal, state, or local laws for the purpose of energy assistance, including WHEAP. Do not count payments specifically designated for heating/electric costs. • Payments made to children of Vietnam Veterans born with spina bifida. • VISTA income. • AmeriCorps income. • Base pay of military personnel called to temporary active duty when the individual is not in the household on date of application and when the temporary assignment will be for 60 days or more. • Foster Care Payments for minor(s). • Title V Senior Community Service Employment Program (SCSEP income, formerly Green Thumb). • Wisconsin Senior Employment Program (WISE) • Payments to volunteers under Title II (RSVP, foster grandparents, and other) and Title III (SCORE and AGE) of the Domestic Volunteer Services Act of 1973 (P.L.93-113) as amended. • Youth Incentive Entitlement Pilot Projects, Youth Community Conservation and Improvement Projects, Summer Youth Employment Program, and reimbursement of expenses provided under the Workforce Innovation and Opportunity Act (WIOA) and Wisconsin Conservation Corps. • Uniform Relocation Assistance and Property Acquisition Policy Act of 1970 (P.L. 92-646, section 216). • Alaska Native Claim Settlement Act (P.L. 92-203, Section 21(a)). • Sub-marginal land of the United States held in trust for certain Indian tribes (P.L. 94-114, Section 6). • Retroactive DEFRA payments. • Payments made under P.L. 100-383 Wartime Relocation of Citizens. These are restitution payments made by the U.S. government to individual Japanese-Americans or their survivors and Aleuts who were interned or relocated during World War II. • Monies received as a result of P.L. 101-41, Puyallup Tribe of Indians Settlement Act of 1989.

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Revised: August 2025 Ignored Income Types • Veteran’s Aid and Attendance is ignored regardless of whether the aide/caregiver is a household member. • Certain government payments are counted income when the annual amount is equal to or greater than $120. Anything less than $120 is ignored. • DNR programs that pay royalties (e.g., stumpage) • USDA programs (e.g., crop disaster relief programs) • Agriculture programs (e.g., CRP) • Tax credits – tax credits such as farmland preservation and homestead credit claimed on Wisconsin income taxes. In-kind Income Do not count any gain or benefit that is not in the form of money payable directly to the household, such as: meals, clothing, housing, or garden produce. This includes but is not limited to: • Benefits received from the supplemental food program for Women, Infants, and Children (WIC) • FoodShare (Food Stamps) benefits Jury Duty Ignore any payments received for performing jury duty. If any counted income is paid during jury duty, the income is counted as normal. See Section 3.3.7 Income Counted Table. Kinship Care Cash benefit paid to caretaker relatives of minor children. Count the child in the household. Land Rent Income from land used for, including but not limited to, cash crop fields or pastured livestock. Ignore annual amount earned if less than $120; count as income if annual earned amount is $120 or more. Loans Ignore all loans including, but not limited to, student loans and reverse mortgages a person received in the prior month test period from private individuals or business sources. (This includes advances on a credit card.) Lump Sum Payments, Non-recurring There are some lump sum payments that are counted as income, but most are not. Examples of not counted lump sum payments include: • Income tax refunds (paid in lump sums or weekly) • Rebates • Earned Income Credits (EIC) paid in lump sum or weekly • Employer new-hire sign-on bonus • U.S. military (re-)enlistment bonus • Insurance settlement • One-time distribution from an inherited IRA • Estate inheritances • Trust funds, if the payment is a non-recurring lump sum • Refunds of security deposits on rental property or utilities • Retroactive Social Security, Public Assistance, or unemployment compensation payments+

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61 Revised: August 2025 Ignored Income Types • Severance pay • Tax intercept • Homestead Tax Credit +If the lump sum payment includes an amount paid specifically for the prior month test period, that portion is counted as income. Medicaid Purchase Plan (MAPP) Income Wisconsin’s Medicaid Purchase Plan (MAPP) offers people with disabilities, who are working or interested in working, the opportunity to buy health care coverage through the Wisconsin Medicaid Program. A person meets the work requirement for MAPP if engaged in a work activity at least one time per month. Any wages earned to meet this requirement shall not be counted on the application. Medical Attendants or Caregivers for Individuals with a Disability • Payments to a disabled person for the services of a medical attendant or live-in medical aide when the money is paid in total to the attendant or aid for services rendered are ignored. • Payments to a medical aide or caregiver for their services are ignored when living in the home of the disabled person. Agencies may contact the HE+ Help Desk to request an exception. Payments Made to a Third Party • Rent payments paid by a relative who is not a household member. • Payments by a government agency to a child caring institution providing day care for a household member. • Payments of a household's medical bills made directly to a hospital by an insurance company. Refunds and Overpayments If overpayments are received in the prior month test period that the applicant is responsible to re-pay, do not count the amount of the overpayment. If repayment of overpayments is withheld from an assistance payment or other source of income, count the full amount of the income before the overpayment is removed. Reimbursements (Money Paid to the Household for Incurred Expense) As long as the payment is not more than what the household actually spent and is not for normal household living expenses or shelter costs (rent, clothing, or food eaten at home). If the reimbursement was more than the actual expense, count the extra as income. Reimbursement examples: • Flat allowances or per diem for job or training related expenses such as travel, uniforms, and transportation to and from a job or training site, including travel expenses of migrant workers • Out-of-pocket expenses incurred by volunteers • Reimbursement or allowances for students for specific education expenses, i.e., travel or books • Medical and dependent care • Services provided under federal Block Grant programs • Respite Care received to pay for services

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Revised: August 2025 Ignored Income Types Student Income or Support Do not count financial aid such as scholarships, educational grants, fellowships, veterans’ educational benefits (including educational subsistence allowances), ROTC scholarships, student loans, or book reimbursements as income for student(s).

Stipends received by a student are counted income, even if the source is ROTC. Sub-Housing Utility Allowance/Reimbursement Do not count the heating/electric allowance/reimbursement as income. Subsidized Guardianship Payments Ongoing payments to persons becoming legal guardians of children in foster care, similar to the adoption assistance program for children who are adopted. The target population is children placed with relatives licensed as foster parents. Count the children in the household; do not count the subsidized guardianship payments. Supplemental Security Income Exceptional Expense (SSI-E) When received, SSI-E benefit must not be included as part of the state SSI income. Do not enter the SSI-E income amount.

$-95.99 for individuals $-345.35 for couples ($172.67 for each person) $-49.34 for couple/one spouse eligible Tribal per Capita If the total gross amount received in the prior 12 months or previous tax year is $2,000 or less, treat as ignored income. If over $2,000, the first $2,000 of tribal per capita is ignored income; anything over in the same year is counted income. Divide by 12 to get a monthly amount. Wages and Salaries When households receive an extra check from wage income in the test period, workers shall ignore the first check received. Example: For workers who are paid biweekly with check received on 5/1, 5/15, and 5/29 – ignore the check received on 5/1. If the household member is paid on a weekly basis and receives 5 checks in a month, ignore the first check and count the last four. NOTE: HE+ System Notes are required to explain the reason for the ignored check. • Paid weekly – count four most recent checks received (use checks with the pay date closest to the date of the application) • Paid bi-weekly – count two most recent checks received (use checks with the pay date closest to the date of the application) Unemployment Compensation All received unemployment compensation.

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63 Revised: August 2025 Chapter 4 | Application Process 4.1 General Application Rules 4.1.1 How to Apply A household may apply for energy assistance by completing a paper version of the HE+ Application, completing an online application, or participating in an interview with a WHEAP agency representative either in person or by phone. If the application is missing required information, the HE+ System Incomplete Notification/Notice must be provided to the customer and must identify the missing information and the timeframe to provide the missing information. In HE+ System Notes, identify the missing information.

Zero-income households’ applications require agency contact with the customer. If an applicant mailed an application or submitted an online application, a worker shall contact the applicant by phone to complete the application. If the applicant is not available, the worker shall create the application and leave the application as “Pending.”

For mailed applications, when the interaction of the application is complete, workers shall change the “Outreach Type” to phone or site where the interaction took place and add System Notes to explain that the new application replaces the paper application. For online applications, the worker does not change the “Outreach Type” when the interaction is complete; the “Outreach Type” remains as “Online.”

NOTE: The Certification Page from the paper application is still valid for the application, and the date signed may be completed once the worker has verified the application with the applicant. See Section 4.4.29 for self-certification guidance when a paper application is received.

4.1.2 Where to Apply Households must apply through an approved WHEAP agency for the county/tribe where they reside or apply online.

4.1.3 When to Apply Households have the right to apply at any time, regardless of whether the heating season has ended. Agencies should encourage households to apply. Early applications may be taken once the Division has determined the early application start date. See Chapter 1 for more information. Applications dated after May 15 may determine eligibility for Prevention Assistance, HE+ Program Services, and Weatherization referrals.

4.1.4 Multiple Applications A household may apply multiple times if not deemed eligible on earlier applications. Households have the right to apply throughout the year. For an application to be considered for regular heat/electric benefits it must be initiated before the end of the heating season.

Duplicate applications received by the local agency shall be uploaded and processed in the HE+ System with any information provided by the applicant unless the household already has a paid application, in which case the agency may only upload the application. Contact the HE+ Help Desk

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Revised: August 2025 if you are unable to upload document(s) into the HE+ System. Contact shall be made with the household to confirm if the application submittal is because of a possible crisis need. If the applicant chooses to withdraw the application, the application must still be entered in the HE+ System. Exception: see online application.

4.1.5 Regular WHEAP Benefits WHEAP-eligible applicants may receive one regular heating and one electric benefit provided the application is initiated before the end of the heating season and LIHEAP or PB funds are available during the heating season. Once a household is determined to be WHEAP eligible, the household remains eligible for Crisis Assistance for the duration of the program year regardless of the date of the application. An application becomes ineligible for additional benefits when any household member, including the case head, is deceased. A new application shall be taken to establish eligibility for the remaining household members. Eligibility does not ensure the provision of a crisis benefit. See Section 7.3.8.

4.1.6 Weatherization Eligibility At the time an applicant’s HE+ Application is approved, the address reported on the HE+ Application is referred for Weatherization services. Referrals for Weatherization services extend for 12 months following the date of the approved HE+ Application. If an HE+ eligible household moves, the Weatherization referral does not automatically carry to the new address. The household may re-apply during the same program year to determine eligibility for Weatherization Assistance at the new address by completing an HE+ Application through the local agency. All applications must contain current, complete, and accurate information based on the date of the application. See the Weatherization Program Manual for restrictions regarding previously weatherized units.

Weatherization status associated with the address displays on the application after the address fields. More details may be found via the Referral Details tab/section. The “Referral” permissions must be added in order to see the Referral Details tab. WHEAP agencies shall work with their weatherization agencies to use and understand the information from the referral search function. WHEAP agencies are encouraged to work closely with their weatherization agencies to help identify and refer homes for Weatherization services.

4.1.7 Limitations There is no entitlement to WHEAP or Weatherization Assistance. Being eligible does not mean Regular WHEAP Benefits, Crisis Assistance, HE+ Program Services, or Weatherization benefits will be provided.

4.1.8 Fair Hearings If the individual believes their regular application has not been processed in a timely manner, has been incorrectly denied, or had an error in determining eligibility; their payment is incorrect; or their crisis request was not processed in a timely manner, they may request a fair hearing (see Section 2.8.2).

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65 Revised: August 2025 Local agencies shall work with the customer in an effort to resolve the issue prior to the Division of Hearings and Appeals (DHA) hearing.

4.1.9 Application Processing Applications are to be entered/processed in the chronological order in which they are received. The application completed with the first chronological date, from applicants who file more than one application, will have precedence in processing. See Section 4.3.4.

All applications are to be entered into the HE+ System within 30 days (see Section 4.3.4) after the application process is started. Any application materials mailed, faxed, dropped off at the agency, or otherwise provided to the agency outside of the original appointment, must be date stamped upon receipt.

Each application and each section of the application must be completed to the maximum extent possible regardless of information that may cause a denial of benefits. The local WHEAP agency must ensure each application is complete in all parts unless the applicant withdraws the application or fails to provide required information within 30 days of the application date.

All applications received in the early application process shall be entered into the HE+ System prior to October 31. In addition, missing information for incomplete early applications can be received until October 31 to be considered complete.

NOTE: See Section 4.3.4 for additional information on processing online applications.

4.1.10 Fraud Prevention Any application for a current contracted agency employee, relative of an agency employee, former contracted agency employee, or a friend of an agency employee shall be reviewed and approved by a staff person at a supervisory level or higher and entered into the HE+ System by someone holding the “Supervisor” permission. This permission may be held by no more than two* WHEAP staff persons of a supervisory role within the agency. In addition, an HE+ System Note indicating the manager/supervisor who reviewed the application must be entered. This restriction applies to any actions related to the individual’s Regular WHEAP Benefits, Crisis Assistance, and HE+ Program Services applications.

All agency staff who work with WHEAP are required to agree to the Conflict of Interest Policy/Non- Disclosure Agreement. (For more information refer to Section 9.5.1.1 and Appendix A.)

If the only agency person with the “Supervisor” permission is faced with taking an HE+ Application from their friend or family member, contact the HE+ Help Desk for guidance before taking the application.

*If an exception is needed to this limit, please contact the HE+ Help Desk. The request must be submitted on an annual basis.

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Revised: August 2025 4.2 Application Formats 4.2.1 Interactive An interactive application contains the same information as the paper application form that is located on the Division website and is filled out during an interview process with a WHEAP intake worker. The application is interactive when the information is entered into the HE+ System during a phone or face-to-face interview.

NOTE: See Section 4.3.4 for additional information on processing online applications.

4.2.2 HE+ Application (Long Form) The long form HE+ Application is the paper version of the application in the secured HE+ System. HE+ Application forms shall not be altered without prior approval by the Division. WHEAP agencies may use the paper form to conduct a mailed application or to conduct intake when the HE+ System is not accessible. If the paper version is used in a face-to-face or phone appointment, the “Is Interactive” field shall be entered as “No.” If an applicant submits a paper application form or any other documentation, that form must be uploaded to the application in the HE+ System even if the application is incomplete or will deny for another reason.

The Division periodically updates the HE+ Application form.

The Certification Page must be signed by applicants before the application is considered complete. Do not complete the “Sign Date” field or submit the application until the applicant returns the completed, signed, and dated Certification Page.

Telephonic signatures are allowed for the Certification Page. See Section 2.6.

The Spanish version of the HE+ Application is available for applicants but does not replace the policy requirement that agencies must have a method to orally communicate with persons with limited English proficiency (LEP). See Section 9.2.3 for more information.

NOTE: An application without an SSN for the case head does not meet the minimum application requirements and is not a valid application.

4.2.3 HE+ Recertification Application Form The HE+ Recertification Form was designed only for use with fixed income households where the applicants: 1. Are at the same address as the prior program year’s application, 2. Have no change in the household member composition, 3. Have no minor household members, and 4. Only receive income from one or more of the following income types:

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67 Revised: August 2025 a. Social Security including SSDI, SSI b. Dividends/interest c. Pension d. Veterans benefits

All instructions and guidance in this WHEAP Manual apply to the HE+ Recertification Form in the same manner as they do to the HE+ Application Long Form. The HE+ Recertification Form is located on the HE+ TTA website under WHEAP │ Forms. The HE+ Recertification Form shall not be altered without approval by DEHCR.

If an applicant submits an HE+ Recertification Form or any other documentation, that form must be uploaded to the application in the HE+ System even if the application is incomplete or will deny for another reason.

When an HE+ Recertification Form is submitted and the agency determines the household does not meet the HE+ Recertification Form criteria, a full application process must be conducted. The application is incomplete until all information is verified. The HE+ Recertification Form must be uploaded into the HE+ System. The agency documents in HE+ System Notes how the full application process was conducted.

4.2.4 Automated Applications Households a) whose income in the previous year came only from Social Security (retirement) and/or Veterans benefits, b) who receive gas and electric service from one of the IOUs, which include Alliant, Madison Gas and Electric (MG&E), Xcel, Wisconsin Public Service (WPS), and We Energies, and c) who have the same housing characteristics as the previous year (have not moved), may be provided with automated WHEAP benefits without being required to submit a new application. Automated applications are processed for eligible households for two consecutive program years; customers must apply via another method after having automated applications for two consecutive program years. The application date and “Sign Date” for the automated applications is the date that the HE+ System created the automated applications.

The automated application households are identified from the previous year’s data. The utilities verify the household is at the same meter and provide the energy account information. The local WHEAP agency is not required to take an application for these households.

The Division mails a letter to the automated application customers upon creation of their automated application. See Appendix G for a template of the automated application customer letter. If the local WHEAP agency is contacted by the customer stating the information on the letter differs from their current information, the local WHEAP agency shall complete the following: • Update and save the automated application in the HE+ System • Request additional documentation, if warranted • Request a new Certification Page • Document with an HE+ System Note that information was updated and requested

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Revised: August 2025 Any documentation the customer provides must be uploaded to the application in the HE+ System even if the application is incomplete or will deny for another reason.

4.2.5 Phone Applications Phone applications may be accepted. Phone applications may be interactive if the data is entered directly into the HE+ System during the interview. • The application date is the date of the phone interview. • The application needs to be “saved,” which will put it into “Pending.” • Send the Certification Page to the applicant with requests for additional documentation. If the phone application is conducted interactively, using an HE+ System-generated Certification Page is the preferred method. Document with an HE+ System Note that information was requested. See Section 2.6.

If the applicant returns the information within 30 days, enter the additional information, save and submit the application, and then “Accept Benefits” for payment. If the documentation is not returned within 30 days, the HE+ System will deny the application as incomplete. The applicant will have to reapply.

4.2.6 Abbreviated Applications Households who meet the following criteria may apply using the abbreviated process: • Households whose only income reported in the previous year is fixed income o As defined in WHEAP policy, fixed income includes Social Security (SSDI, SSI), Dividends/Interest, Pensions, and/or Veterans benefits • Households that have had no changes to the household members or type of income reported from the previous year • Households that have the same housing characteristics as the previous year (have not moved)

A new signature is required after two consecutive years.

Eligible customers are not required to submit a new application form. The WHEAP agency shall identify eligible customers by using previous year’s data; all application information received over the phone is required to be verified by the local WHEAP agency.

A new Certification Page is required and shall be uploaded after two consecutive years.

4.2.7 Online Application Applicants may submit applications online via the online application portal.

Online applications are entered into a customer web portal that interfaces with the HE+ System (secured site). The interactive indicator is automatically set by the HE+ System as interactive because the applicant has entered most of the application information online. During the validation process, the information is directly imported into the HE+ System by the local WHEAP agency. • The application date is the date the customer submits the online application (HE+ System-

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69 Revised: August 2025 generated) • The 30 days allowed to complete an application begins as soon as the applicant submits the online application • Validation of an online application is the required first step of creating an HE+ Application in the HE+ System • The application needs to be “saved” which puts it into “Pending” state and status

4.2.8 File Retention Documents shall be uploaded into the HE+ System for file retention. Agencies are not required to retain documents as a paper file once the document has been uploaded.

When applicable, the following documents are required to be uploaded to the HE+ System: • Paper applications • Authorized Representation and/or Power of Attorney (POA) documentation • ZIF(s) for all adult household members • Documents used to verify income (paystubs, wage printouts, S-GIRF, tax forms, and/or supporting schedules, etc.) • Certification Page (signed by customers) • WHEAP Affidavit of Lost, Destroyed or Stolen Benefits Form (shall be uploaded to the “Other WHEAP Documents” repository)

For additional record keeping requirements, see Section 9.5.3.

4.3 Processing an Application 4.3.1 Access The secured database/website where applications are stored and from which applications are processed is referred to as the HE+ System and is located online. Access to the HE+ System site is controlled by a security agreement, a username, security image, and password. Incorrectly entering the login information five times will result in the profile being locked. Users should contact their agency HE+ System PMA to unlock the profile. The local PMA is responsible for creating users, assigning permissions, and verifying intake worker PII. The creation of or changes to a PMA in the HE+ System must be completed by the Division. Any updates to agency PMAs must be submitted in writing to the HE+ Help Desk. As part of the security on the HE+ System, all local WHEAP workers with Application Intake permissions will be required to enter their SSN and DOB upon their first log on. Workers’ SSNs will be visible to only the PMA for the territories assigned to that user. Any changes in user system permissions will result in the user needing to agree to the newly assigned permissions and the Conflict of Interest/Non-Disclosure Agreement statement (see Section 9.5.1.1).

The Division maintains a non-secured, or public, website. A substantial amount of information is available on this site for both WHEAP and WAP.

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Revised: August 2025 4.3.2 Verification of Information The application information entered into the HE+ System must be true and correct. WHEAP workers are to verify all information before it is entered into the HE+ System. Workers shall upload copies of all documents to the HE+ System as proof the information entered is correct. • All income documentation is required to be retained as a document upload to the HE+ System. See Section 3.3.5.4. • Additional application-related documents that require upload to the HE+ System include: o ZIFs o Paper applications o Certification Page (signed by customer) (for more guidance see Section 4.4.29) o Authorization of Representation forms, when applicable

If a worker discovers that verified application information differs from the customer-submitted HE+ Application or if additional clarification is needed, discrepancies and clarification shall be documented in HE+ System Notes.

If the information entered on the current year application differs from application history, discrepancies shall be documented in HE+ System Notes.

NOTE: Agencies are no longer required to retain paper files due to the HE+ System upload requirements. For additional file retention requirements, see Section 4.2.8.

4.3.3 Validation of Applicant Data Workers are required to use data validation functions that are available in the HE+ System when processing HE+ Applications. For example, the HE+ System uses the MCI to validate SSNs and the WEFI web service to confirm information about the status of IOU accounts. Information displayed as part of the data validation must be reviewed for accuracy prior to use for application processing. Applications that require bypassing the data validation functions must have documented justification in HE+ System Notes. The data validation functions are only to be used to validate and retrieve data relevant to an HE+ Application. Misuse may result in inactivation of a worker’s WHEAP user profile and may include further disciplinary action.

4.3.4 Online Application Processing If an online application is received with incomplete information and/or verifications, an Incomplete Notification/Notice (see Section 4.1.1) shall be sent informing the applicant of what verifications are required to complete the online verification. Workers may also provide verbal notice of what verifications are required to complete the online verification. If the agency provides verbal notice instead of written notification, workers shall enter HE+ System Notes stating the customer was provided with a verbal notice and describing the missing application information.

4.3.4.1 Online Application Statuses • In Progress – The customer has started an online application in the online application portal. The customer has not yet submitted their online application. Applications that are in progress will expire after 30 days of inactivity.

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71 Revised: August 2025 • Submitted – The customer has submitted an online application, and the local agency may begin the validation process. • Under Review – The worker has validated some of the information. • Application Created – The worker has completed the validation and has created an application in the HE+ System. • Void – The worker has voided the online application in the HE+ System. HE+ System Notes are required to explain why the online application was voided and when the customer contact occurred. • Application Expired – After an online application has been in progress for 31 days, the HE+ System updates to this status and the customer must create a new online application.

NOTE: An online application may be voided if the customer has already received Regular WHEAP Benefits in the same program year and is not applying for Weatherization services at a new address. An HE+ System Note is required to explain why the online application was voided and when the customer contact occurred.

4.3.4.2 Updating Online Statuses The HE+ System sends a text message and/or email to customers to notify them when the status of an online application is updated. The following instances result in an HE+ System-generated notification sent to the customer: • “Submitted” applications changed to “In Progress” • “Submitted” applications changed to “Void” • “In Progress” applications changed to “Void”

Agencies are required to contact the customer before changing the status of an online application. HE+ System Notes shall be entered explaining why the status* was changed and when the customer was contacted.

*HE+ System Notes and customer contact is required when any online application statuses are changed except when the status is changed from “Submitted” to “Application Created.”

4.3.4.3 Validating Online Applications Validation of information is required before an HE+ Application can be created in the HE+ System.

Agency staff are required to validate the address, all household members’ SSNs, and landlord information (if applicable) prior to creating an HE+ Application in the HE+ System. An online application can only be validated if the applicant provides a correct SSN for all household members.

Agencies processing applications shall review and contact all household members who are over the age of 18 to verify if they receive or do not receive any type of income. HE+ System Notes shall be entered documenting the date the customer was contacted and the outcome of the call.

If an online application is received with incomplete information and/or verifications, an Incomplete

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Revised: August 2025 Notification/Notice (see Section 4.1.1) shall be sent informing the applicant of what verifications are required to complete the online verification. Workers may also provide verbal notice of what verifications are required to complete the online verification. If the agency provides verbal notice instead of written notification, workers shall enter HE+ System Notes stating the customer was provided with a verbal notice and describing the missing application information.

Online Applications with Incorrect SSN When an online application has an incorrect SSN that is preventing conversion to an application in the HE+ System, the online application status shall be changed to “In Progress” and the customer shall be instructed to correct this information. This includes household members with no SSN provided or SSN exception reason “Other” because the SSN was not available at the time the application was entered. If the applicant does not have an SSN for the child and an exception is being requested due to a delay in obtaining the SSN, the worker may proceed with converting to an application.

Follow these steps: • The WHEAP agency shall notify the customer that an SSN on the application appears to be incorrect and needs to be corrected. Explain that the application status will be changed to “In Progress” for them to review and edit the application. Advise the customer that they will receive a general message that their application needs additional information. • The WHEAP agency shall change the online status to “In Progress.” The applicant receives notification by the communication method that they selected when they completed their online application. The message is not detailed, which is why it is important that the agency contacts the customer before taking action. • The applicant shall edit the online application to correct the SSN for either themselves or for a household member(s) and resubmit the online application.

Online Applications with Incomplete or Incorrect Landlord Information When a customer enters incomplete landlord information or selects “I Don’t Know,” agency staff shall edit the information and complete a landlord search before continuing to process the online application. The application shall not be put back to “In Progress” status. The worker shall contact the customer if additional information is needed.

Duplicate Online Applications If an online application is received for the same program year and the household already has a “Paid” application and is not applying for Weatherization services, the agency staff may void the online application. The following steps must be completed prior to updating an online application status to “Void” in the HE+ System: 1. The WHEAP agency shall notify the customer that a duplicate online application has been received for the same program year and explain that applicants are only eligible for one Regular WHEAP Benefit during each program year. 2. Discuss any Crisis and/or Weatherization Assistance needs (if applicable). 3. Enter HE+ System Notes that explain why the online application was voided and when customer contact occurred.

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73 Revised: August 2025 4.3.5 Updating Applications Created by Another Agency When agencies cover the same service territory, they may update and/or complete and submit a pending HE+ Application created by another agency serving the same territory when the customer contacts the WHEAP agency and/or the WHEAP agency obtains all required documents. The agency submitting the application is responsible for any non-compliance with HE+ policy.

4.3.5.1 Updating an Application Created by Another Agency If an agency obtains required documents for an HE+ Application created by another agency within the same service territory and is unable to complete the application, the agency may take the following actions: 1. Edit and save the application to take “ownership” and to activate the document upload functionality. 2. Upload documents to the application in the associated repository. Agency staff shall not enter income values unless all verifications are received for the income type in the test period. 3. Send an email to the associated WHEAP Coordinator about the document upload to the agency that created the application. For emails to Energy Services, Inc., please send to: support@wheap.help. The email subject shall be: (Name of territory) Verification uploaded – PID #. For example, Ashland County Verification uploaded – PID 111111. The email shall include the following information: a. Application number b. A description of the document(s) uploaded to the application c. The date the document(s) were received from the customer

Once notified of the document upload, the original agency will retake “ownership” of the application by editing and saving the application. Agency staff shall review the application to ensure the information is accurate prior to submitting for benefits.

NOTE: The agency submitting the application shall not change the original Outreach Type. The agency submitting the application is responsible for any non-compliance with HE+ policy.

4.3.5.2 Deleting or Cancelling an Application Created by Another Agency An agency shall not delete or conduct a cancel/refund on an HE+ Application created by another agency without first consulting with the HE+ Help Desk.

4.4 Field-by-Field Instructions/Guidelines 4.4.1 Application Date Table 4.1: Determining Application Date Based on Application Format Application Format Application Date HE+ System application (i.e., interactive application) The date the interactive interview takes place. Phone application (paper or interactive) The date of the phone interview.

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Revised: August 2025 Application Format Application Date Paper application taken by WHEAP worker (at outreach site or because the HE+ System is down) The date the interview takes place. Paper application completed by applicant and mailed or dropped off at agency The date the application was received by the agency. Each application must be date stamped upon receipt. Online application The date the applicant submitted the online application.

4.4.2 Worker Number Up to a four-digit local agency assigned number, individualized for each worker, can be entered.

4.4.3 Interactive Interview To be interactive, information provided by the applicant must be entered into the HE+ System during the interview. An interactive interview may be face-to-face or over the phone.

4.4.4 Outreach Indicator The outreach indicator assists the local agency in tracking the method in which an application is received. • Local Agency – Application process is conducted face-to-face at the county/tribal office. • Alternate Site – Application interview is conducted face-to-face at a location other than the main county/tribal office. For WHEAP purposes, elderly meal sites or other outreach sites are alternate sites. • Home Visit – Application is taken face-to-face in the applicant's home. • Mail – Applications that are submitted to the agency via United States Postal Service (USPS) mail or dropped off at the front desk of the agency. • Phone – Applications that are taken over the phone. • Online – Applications that are received online via the online application portal. • Automated – Applications that are processed by the HE+ System for a specified subset of prior year recipients.

4.4.5 Withdrawn “Withdrawn” applications must be entered into the HE+ System. An applicant may choose to withdraw the application any time prior to extraction. “Withdrawn” applications should always have at least the minimum information entered. All information provided should be entered even if the application will be withdrawn.

HE+ System Notes about the reason for the withdrawal must be entered. An HE+ System- generated denial letter is sent to the applicant.

When a current year application is withdrawn, it is not possible to create another application on the HE+ System until the “Withdrawn” application is extracted.

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75 Revised: August 2025 4.4.6 Social Security Number (SSN) SSNs must be verified through the HE+ System. The HE+ System will prompt a web call to verify each SSN listed on the application. See Section 3.2.3 for more information on verifying SSNs.

4.4.7 Field #1 Territory (County/Tribe) Applicants must apply in the county or tribe where they reside on the date of application.

4.4.8 Field #2 Applicant (First and Last Name) The first and last name entered in this field shall be the legal name of the applicant. Any non-legal form of the name shall be entered in Field #3, Alias.

4.4.9 Field #3 Alias First Name Field #3 shall be used to enter any name other than their legal name that the applicant elects to be known as. For example, James is the legal name entered in Field #2, and Jim is the Alias entered in Field #3.

4.4.10 Field #4 Primary Phone/Secondary Phone Enter the primary telephone number provided by the applicant.

4.4.11 Field #5 Email Address Providing an email address is optional. The applicant should only provide their email address if they are permitting the agency and/or the Division to send emails related to HE+ programs. Email addresses will not be shared outside of HE+ programs.

4.4.12 Field #6 Preferred Communication Select the preferred method of communication for the household. This field is not required. By providing this information the applicant is providing consent to contact the household via the selected method.

4.4.13 Field #7 Housing Type Select the housing type that best describes the applicant's residence. • “Single family” for a one-unit (detached) structure. • “2- to 4-unit building” for a small apartment building (or condominium),duplex building (2 units), triplex building (3 units), or four-unit building. If the structure has business use in one or more of the units, check the appropriate building type based on the number of units; for example, if there is a bar on the first floor and a residential unit on the second floor, this is considered a duplex (2 units). The HE+ System requires an entry in “Unit Count” which represents the number of units in the building where the customer resides and must be 2, 3, or 4. • “Apartment or multi-unit building” (including condominiums) for a building with more than four units in the building. The HE+ System requires an entry in “Unit Count” which represents the number of units in the building where the customer resides. See business use information in the example above.

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Revised: August 2025 • “Mobile home” for a mobile home (trailer in the old terminology) or a manufactured house (new terminology) that was towed to the site (even if it was more than one part that was tied together at the site). Use mobile home for units on private land or in mobile home parks. If the structure is a modular home, not a mobile home, check “single family.” • “Motel or Camper/RV” for a motel, hotel, or camper/recreational vehicle. To be eligible, this must be the applicant’s primary residence, and the applicant must have an energy burden. Agencies must add an HE+ System Note describing the customer’s situation and contact the HE+ Help Desk for approval for all applicants with this housing type. This housing type is not eligible for referrals to Weatherization or HE+ Program Services. • “Ineligible Dwelling” for an ineligible dwelling type. Examples include a motel room or camper/RV that is not a primary residence or has no energy burden, tent, or other ineligible type, including an applicant’s non-primary residence.

When a dwelling does not correspond to one of the standard housing types, pick the type that seems closest and document in HE+ System Notes the reason for selecting that housing type. Guidance may also be provided by the HE+ Help Desk.

Refer to the Dwelling Eligibility Table in Section 3.2.2.1.

4.4.14 Field #8 Mailing Address The mailing address is where the applicant gets their mail at the time of the application. The applicant's mailing address may be different from the residence address (for example, a PO Box). If the mailing address differs from the residence address and is not a PO Box, an HE+ System Note must be added to explain why the two addresses are different.

If the envelope icon by the address is red, data entry may be continued on the application, but the application will not extract until the mailing address has been validated or overridden in the HE+ System. When requesting an override, an HE+ System Address Note must be added to document how the mailing address was verified. The United States Postal Service website or confirmation from the post office that the address is deliverable are the only allowable sources for address validation. HE+ System Notes will be reviewed by Division staff to assist in validating the address.

If the applicant has their mail delivered to a legal guardian, protective payee, or an authorized representative, enter that person’s address in this field.

4.4.15 Field #9 Residence Address Enter the (physical) address where the applicant resides at the time of the application by clicking on the house icon. Do not enter a PO Box number in the residence address. Enter only the physical address (see Field #8, Mailing Address).

Compare and verify the street address from the prior year. If different, enter the correct street address. When changing an address, the HE+ System will ask if you wish to clear all fields related to the dwelling. If the applicant has moved, select “Yes” to clear out all housing-related fields including fuel account information.

The residence address represents the applicant's location of residence on the date of application.

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77 Revised: August 2025 If the applicant moves before the benefit has been paid, change the mailing address only (see Field #8, Mailing Address). If the applicant moves after the benefit has been paid, add HE+ System Notes.

If the residence address returns as a duplicate with a different case head during the same heating season, an HE+ System Note shall be added to demonstrate the questions asked to determine the validity of two paid cases at the same address in the same heating season (e.g., first applicant applied in October, second applicant applies in March and states that they moved in during February). DO NOT provide information to the applicant regarding any other applicants who have applied at the same address.

4.4.16 Field #10 Ownership Type: Own or Rent If the customer lives in a mobile home and owns the unit, indicate they are an owner even if they pay lot rent in a mobile home park.

Landlord and/or management company contact information is required for Weatherization referrals. For all rental situations, agencies shall enter the landlord or management company contact information into the HE+ System. The landlord’s or management company’s name, address, and phone number are required. Workers shall enter new landlord information or adopt the existing landlord information. If the existing landlord information is different from what was provided by the customer, workers must contact the HE+ Help Desk. If landlord or property management company information is not provided, the application should remain in “Pending” status until the customer provides the required information.

For applications with “Direct Pay Accounts,” workers shall not allow an application to deny if the customer does not provide landlord information within 30 days of the application date. Applications may need to be reinstated if denied incorrectly for not providing landlord information (see Section 7.3.2 for more information). Workers shall document in HE+ System Notes that the landlord or property management record was not added to the HE+ System because the applicant could not provide all three data elements (name, address, and phone number) and include any partial information provided.

For applications with “Rental payment includes energy in the monthly rent” and/or “Separate payment is made to the landlord…” workers are required to enter landlord or management company contact information. Customers are required to provide verification for the following payment methods, and the means of verification must be indicated in HE+ System Notes: • Rental payment includes energy in the monthly rent • Separate payment is made to the landlord, mobile home park owner • Do not pay

Verification may include, but is not limited to: • Observation of utility allowance on Form 50058 or Form 50059 • Observation of a lease or rental agreement • Verbal or written contact with the landlord

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Revised: August 2025 • In some cases, the heating vendor can verify if heat is included

NOTE: Observation of previous years’ information is not an acceptable form of verification. New verification must be obtained.

NOTE: For multi-unit buildings, the agency may obtain information from the landlord/management company verifying that all units have heat and/or electric included in rent, a separate payment is made to landlord, or are “do not pay.” This verification may be used for all units within the building and must be obtained on an annual basis. The means of verification must be indicated in HE+ System Notes.

When verifying that the heat is included in rent or separate payment to landlord, workers shall verify with the landlord or vendor what the primary heating type is for that dwelling and include that verification in HE+ System Notes.

4.4.17 Field #11 Room Count Count and enter the number of rooms in the applicant’s dwelling. Do not count bathrooms, unfinished basements, entryways, hallways, laundry rooms, porches, closets, or unheated attics. Do not count rooms that contain a swimming pool, hot tubs, or spa. • If the housing type selected is “Motel or Camper/RV,” the number of rooms must equal one. The HE+ System will not accept a value greater than one. • The maximum number of rooms the HE+ System will accept is nine. For a household that has more than nine rooms, enter nine.

If the applicant uses part of the home for business use, do not count rooms that have been used on a regular basis in the last 12 months for business purposes.

Example: If the applicant is the owner of a building which includes rooms the applicant has rented to roomer/boarders or overnight guests ("Bed & Breakfast”), do not count the rented rooms.

To aid in determining an accurate room count for combined living spaces such as kitchen/dining area, great room, studio or efficiency apartment, or other large living space, hypothetically insert a wall(s) separating the spaces. If the residents can utilize the resulting rooms with the same or more utility and without increased inconvenience, the room count shall be counted as more than one room. If the existence of the hypothetical wall would result in a lack of utility and increased inconvenience, the room count should be one. No more than three rooms shall be counted for any open living space.

4.4.18 Field #12 Living Situation Selecting “Are currently in a homeless situation moving to a permanent residence” will not make the applicant ineligible. Document the proof of permanent address in the HE+ System Notes.

4.4.19 Field #13 Is Government Assisted Housing: Rental Assistance There is a broad range of rental assistance programs available to low-income families. Government-assisted housing includes any living situations where the tenant’s rent amount is

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79 Revised: August 2025 determined by their household income and the rest of the rent is subsidized by the federal, state, or local government.

There are projects done under the auspices of the federal Department of Housing and Urban Development (HUD), the Farm Service Agency (FSA), and a variety of other programs including those using Wisconsin Housing and Economic Development Authority (WHEDA) funds. For Section 8 residents, the worker may request a current copy of HUD Form 50058 or Form 50059 to verify their rental assistance. These forms are issued annually; the expiration date (Exp mm/dd/yyyy) on the form can be used to verify that the most current form is provided. Check with the local Housing Authority for the location(s) of building(s) they operate or know about. The WHEDA website lists some subsidized housing units in Wisconsin.

Residents of these buildings may directly pay their utilities, or they may have one or more of the utilities included in the rent. A heating allowance or utility allowance may be provided to the residents, often through an additional reduction in the rent. A copy of Form 50058 and Form 50059 may also be used to verify their utility allowances.

NOTE: If there is no “Utility Allowance” listed on the form, their utilities are included in rent. A copy of their lease or verbal contact with landlord and an HE+ System Note is required to verify which utilities are included in rent. See Appendix C for a copy of Form 50058 and 50059. Do not count utility allowances or reimbursements as income.

4.4.20 Field #14 Guardian Type: Designated Representation If the applicant has a Guardian or Designated Representative, the information should be entered in this field. If the Legal Guardian, Power of Attorney, Protective Payee, or authorized representative is creating the application for the applicant, they will sign the application rather than the applicant. Document in HE+ System Notes what form of verification was viewed for these scenarios (Authorization of Representation/Affidavit of Agent Form, Power of Attorney papers, etc.).

If the form of verification viewed is the Authorization of Representation/Affidavit of Agent Form, the following procedures shall be followed: 1. Document in HE+ System Notes the duration the applicant authorizes the agent. 2. The authorization is valid for all HE+ Applications until the date indicated on the form, not to exceed five program years. 3. If no date was provided for the “Authorization is valid until” date, the authorization is only valid for one application. Document in HE+ System Notes. 4. The form shall be: a. Uploaded into the HE+ System for the duration of the authorization b. Reviewed each program year and made available to the Division upon request

A protective payee is someone designated by the Social Services Agency to assist with or fully handle an applicant’s finances. Enter the name of the representative payee. Do this only if the applicant wants the benefit notice/check sent directly to the representative payee. The benefit notice/check will be sent to the address provided in Field #8, Mailing Address.

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Revised: August 2025 If the case head is a dependent child, enter the parent's name here. A dependent child may be a case head if all adults in the household are ineligible non-citizens and the dependent child is either a citizen or an eligible non-citizen and the child has a valid SSN. The parent/legal guardian of the dependent child who is the case head should sign the Certification Page and an HE+ System Note should state who signed the application. A dependent child should not sign the Certification Page even if they are the case head.

4.4.21 Field #15 Student Situation Students aged 25 and older as of the date of the application are eligible case heads. The applicant’s student status does not need to be verified.

Students under age 25 as of the date of the application are not eligible case heads (applicants) unless they meet specific conditions. This question is intended to help determine if an individual satisfies any of the exceptions. A student could be a household member, not a case head, without the need to satisfy the exceptions for student status. Individuals enrolled in high school are dealt with under the provisions for emancipated minors.

4.4.22 Field #16 Is Child Family Housing If anyone in the household under age 18 is related to any other adult household member, answer “Yes.” If an appropriate relationship exists, the Division can bill the benefit payment to TANF. The paper version of the HE+ Application includes a list of qualifying relationships. Click on “View Relationships” for a list in the HE+ System if unsure what type of relationship qualifies.

4.4.23 Field #17 Total # Household Members The total number of individuals living in the household on the date of application should be entered on the application and shall be entered in the HE+ System. The number of household members entered in the “Household Members” section must match the value entered in Field #17 of the general section. When processing a paper application, all persons listed on page 3 of the paper application form shall be included in the count entered in this field even if waiting for required household member data elements.

4.4.24 Field #18 Is Present Month Income Identify which test period is being used to verify the household income. When selecting “Yes,” the income is verified for the present month. If selecting “No,” the prior month test period is being used. See Section 3.3.2 for the policy exception that allows using the present month as the income test period instead of the prior month.

4.4.25 First 18 Fields The minimum information required in the first 18 fields in order to continue with the application is: • Case Head SSN • Case Head Name, Date of Birth, and Gender • Application Date • Housing Type

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81 Revised: August 2025 • Mailing Address • Residence Address

NOTE: An application without an SSN for the case head does not meet the minimum application requirements and is not a valid application. An application without an SSN for the case head shall not be entered into the HE+ System until an SSN is provided.

4.4.26 Household Members All persons living in the household on the date of application shall be entered in the HE+ System before the application is considered complete. Household members cannot be entered until the required data elements have been provided (name, date of birth, gender, and SSN). Exceptions: temporary household member (see Section 3.2.6.4).

The total number of household members on Field #17 of the general section shall include the household member(s) that cannot be entered because the required household member data elements were not provided at the time of application entry. The application will be incomplete until the required data has been provided. The household member section will not be complete until the number of household members entered matches the number of household members indicated in Field #17 of the general section. See Section 3.2.3.3 for the correct usage of SSN exceptions “Other” and “Religious Exception.” These exceptions shall not be used as a placeholder while waiting for SSN information from the applicant.

NOTE: The HE+ System inserts the case head as a household member. If the case head’s name, date of birth, or citizenship is incorrect, the worker must make the correction in the Household Members section of the application. Information for all household members must be verified.

4.4.26.1 Gender Gender is a self-declared field; enter the gender for each household member as the applicant reports it.

4.4.26.2 Citizenship Type: Citizen/Eligible Non-citizen/Ineligible Non-citizen Include ineligible non-citizens and their income on the application. The HE+ System will not count ineligible non-citizens as a household members, but it will count their income when determining program eligibility and benefit amounts.

4.4.26.3 Ethnicity Type Select the ethnicity that each household member identifies with: Hispanic/Latinx, Non- Hispanic/Non-Latinx, Unknown, or Decline to answer. Decline to answer may be selected if field is not completed by the applicant on the paper application.

4.4.26.4 Race Select the race that each household member identifies with: Asian, Black or African American, Hispanic/Latinx, American Indian or Alaska Native, Multi Race (2 or more), Other, Native Hawaiian or Other Pacific Islander, White, Unknown, or Decline to answer. Decline to answer may be selected if field is not completed by the applicant on the paper application.

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Revised: August 2025 4.4.26.5 Disabled Disability is a self-declaration that their disability limits their life activities. Verification is required if a student claims disability status.

4.4.26.6 FoodShare FoodShare should be marked “Yes” if that person received FoodShare in the month prior to the date of the application.

4.4.26.7 Military Service Military Service includes a person who is serving or has ever served or is a surviving spouse of someone who served in a branch of the United States military as Active Duty, Reserve, or National Guard (Army, Navy, Air Force, Marine Corps, and Coast Guard).

4.4.27 Household Income All household members must report and verify their income received in the test period. For most applicants, this means the month prior to the application date. See Chapter 3 for further clarification on income.

Household members can have multiple sources of income. Enter each income type/source separately for the household member.

The document upload replaces the verification data entry. Enter an HE+ System Note when additional clarification is needed. CARES records, SSA, released Cost of Living Adjustment (COLA), and bank statements may be used to verify the receipt of SSA income types. All income must be entered and verified even if the household appears to be over income. If all the income information is not provided and verified, the application is incomplete and should be left “Pending.” Enter an HE+ System Note to describe what is missing. Income types with zero income for the test period should not be entered as income unless it is self-employment income verified by taxes. Refer to Appendix B for more information on income types.

Agencies processing applications shall review all applications and shall contact all household members who are over the age of 18 to verify if they receive or do not receive any type of income. HE+ System Notes shall be entered documenting the date the customer was contacted and the outcome of the call.

4.4.27.1 Zero Income A zero-income household has no sources of income either earned or unearned in the test period. This includes a household that has only ignored income (see Section 3.3.9).

A household is not zero-income when: • The household has countable income to report. • The only countable income in the household is self-employment income (SE) and the business operated at a loss. Enter SE as the income type and zero for the income amount. This is the only income type that should be entered with zeroes for the test period.

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83 Revised: August 2025 • The household has any other income resulting in a negative amount for the test period, such as child support paid.

If the household is determined to be zero-income, see subsequent Section 4.4.27.2 and Section 4.4.27.3 for requirements of self-certification, the ZIF, and interactive application requirements.

When households report zero income, follow-up with the customer is required to complete the application, unless the application was processed in-person or via phone. See Section 4.4.27.2 regarding how to proceed if a paper application is received for a zero-income household.

4.4.27.2 Self-Certification for Zero-Income Households If a zero-income household is unable to provide third-party verification of an ignored income source (see Section 3.3.9), and after all other avenues of documenting income eligibility are exhausted, self-certification by completing the ZIF is allowable. Agency staff shall enter HE+ System Notes stating the various attempts of obtaining third-party verification.

Third-party verification: Ignored income shall not be entered into the HE+ System as an income record but noted in HE+ System Notes. Examples of third-party verification include: • Student Income – Loan/Grant Award letter/statement • Kinship Care – View check stubs or CARES

If third-party verification is provided of an ignored income source for a zero-income household, agency staff shall upload the verification into the HE+ System under “Zero Income.” That verification is sufficient for the ZIF document upload requirement; while the worker may ask the customer to complete a ZIF, it is not required.

Self-certification: If the household is self-certifying as a zero-income household, the following procedures are suggested: 1. Mailed applications If a zero-income mailed application is received, the worker shall: a. Enter the mailed application into the HE+ System as an incomplete application until the interaction takes place b. Enter HE+ System Notes stating the application is “Pending” for customer interaction c. Contact the customer to confirm income information and to ensure the ZIF has been fully completed and submitted i. If unable to reach the customer, send an Incomplete Notification/Notice (see Section 4.1.1) informing the customer to contact the agency d. Change the “Outreach Type” to phone or site where the interaction took place e. Enter HE+ System Notes stating that the phone interaction was completed and enter any missing ZIF information

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Revised: August 2025 2. Outreach applications If a zero-income application is received at an outreach/alternate site, the worker shall: a. Date stamp and indicate the outreach site at the top of the paper application b. Contact the customer to confirm the income information and to ensure the ZIF has been fully completed and submitted i. If unable to reach the customer, send an Incomplete Notification/Notice (see Section 4.1.1) informing the customer to contact the agency c. Enter the application into the HE+ System as an incomplete “Pending” application until the interaction takes place d. Enter HE+ System Notes stating the application is “Pending” for customer interaction e. Change the “Outreach Type” to phone if the interaction did not take place at the outreach/alternate site f. Enter HE+ System Notes stating that the interaction was completed and enter any missing ZIF information 3. Online applications If a zero-income application is received online, the worker shall: a. Validate the application and create an HE+ Application in the HE+ System b. Contact the customer to confirm income information and to ensure the ZIF has been fully completed and submitted i. If unable to reach the customer, send an Incomplete Notification/Notice (see Section 4.1.1) informing the customer to contact the agency c. Keep the application in “Pending” status until contact has been made and the zero- income information is confirmed d. Despite contacting the customer, keep the outreach type as “Online” e. Enter HE+ System Notes explaining the interaction is required and/or completed and enter any missing ZIF information

4.4.27.3 Use of the Zero Income Form A ZIF shall be completed by each adult household member when the household is determined to be a zero-income household (has no sources of income either earned or unearned). See Section 4.4.27.1 for more information on zero-income households. The agency must retain a copy of the completed ZIF as a document upload to the application in the HE+ System.

The form shall be completed in its entirety to be accepted as verification of how the household is meeting basic living expenses including complete contact information of the individual(s) assisting with monthly expenses. The form should adequately explain how basic living expenses (shelter, heat, utilities, and basic living needs) are being met on a continuous basis. WHEAP agencies should follow up with the individual(s) listed on the ZIF if the form is incomplete or additional information is needed and document in an HE+ System Note the follow-up that was completed.

WHEAP agencies shall use the Division-created ZIF, which can be found on the Division website under Provider Resources │ Energy │ Energy Assistance │ Forms. The ZIF may be used as

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85 Revised: August 2025 written verification of any gift income the customer has received during the test period. Self- declaration of the gift income amounts is allowed. HE+ System Notes are required for self-declared gift income amounts. A written or verbal statement from the gift giver may also be used as verification. The use of the ZIF is optional in other situations, at the agency’s discretion, as a tool to ensure accurate processing of an application.

4.4.28 Energy Fuels (Fuel Page) The fuel page is intended to collect information about fuel use and payment responsibility. It is important to correctly complete all the fuel entries as they can have an influence on the amount of the benefit.

Fuel information is required on all applications, including those for over-income households.

4.4.28.1 Basic Fuel Page Rules 1. For an application to be complete, the electric information needs to be provided. If an applicant does not have electricity in their home, an application can be entered without an electric energy fuel. The worker must make the appropriate selection in the HE+ System to indicate there is no electricity in the home. There must be documentation in HE+ System Notes explaining why no electric fuel type was entered. 2. For an application to be complete, there must be a primary energy fuel (heating) selected.

4.4.28.2 Primary Heating Fuel An applicant may only report one primary fuel type. If the applicant has more than one heating source, the applicant and the agency need to determine which fuel type the applicant uses the most to heat the residence.

In choosing between fuels to declare as the primary heating fuel, consider the following: • When there are two heating units, consider which fuel supplies 50% or more of the household heat. • When there is a farmhouse or outbuildings, there is generally a separate tank and account from the home. • Consider the primary heating unit of the dwelling. The primary heating unit declared on the application affects Weatherization services available for this dwelling. • Should there be a furnace failure, furnace service is only available for the primary heating fuel. When the dwelling is audited for Weatherization services, only the primary heating type identified on the application is included in the audit assessment. • Selecting “wood or other” without a vendor will result in the eligible applicant receiving a single-party check and means the household will not be eligible for any heating Crisis Assistance. An HE+ System Note must be added to identify the fuel type. “Other” fuel types include corn pellets, other biofuels (corn stalks, etc.), or kerosene.

A household may not change the primary fuel type on the application after the benefit has been paid.

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Revised: August 2025 4.4.28.3 Energy Fuel Type Click on the drop-down menu to select the type of fuel that is used for heating and non-heat electric in the house. If an applicant cannot tell the WHEAP agency what fuel type they use, the application should remain in “Pending” status until the applicant notifies the agency of the fuel type. If the applicant does not provide the fuel type to the agency within 30 days, the application will be denied.

Wood pellets and wood chips should be entered as “wood or other.” When selecting “wood or other” as a fuel type, an HE+ System Note must be added to identify the fuel type if the fuel type is not wood. “Other” fuel types include corn pellets, other biofuels (corn stalks, etc.), or kerosene.

If an applicant does not have a relationship with a utility for electrical service, they will not be eligible for an electric benefit. If the only source of electricity is from solar cells, wind power, an extension cord, or a generator, no fuel record shall be entered into the HE+ System, and the worker shall select “No” for the “Has Electric Provider” field. An explanation shall be included in HE+ System Notes as to the reason for this selection.

NOTE: If the customer has a heat pump, please contact the HE+ Help Desk for assistance with identifying the primary heat source.

4.4.28.4 Payment Method Select how the applicant pays for their home heating costs. • Directly pays the bill sent from the energy provider. This choice coupled with the vendor information and the account information will lead to a payment being made to the vendor for the eligible applicant’s account. For non-heating electric, the applicant is eligible for a PB only if the vendor is a participating PB vendor. If they are serviced by a vendor that is not a participating PB vendor, they are directed to contact the electric vendor for participation in that vendor’s Commitment to Community program. o When applicants prove they pay their own heating costs but do not provide documentation of the costs at the time of application, leave the application in “Pending-Unextracted” status. If the worker is still unable to gather the costs, process the application with “zero” fuel costs. An HE+ System Note is required to explain the reason for the “zero” cost entry. • Rental payment includes energy costs in the monthly rent payment and the household does not receive rental assistance. This choice will result in a check being issued to the eligible applicant based on a proxy amount for the heat/electric costs. For non-heating electric costs, the applicant is eligible for a PB only if the vendor providing electricity to this dwelling is a participating PB vendor. • Separate payment is made to the landlord, mobile home park owner, or no direct account with a vendor. This choice will result in a check being issued to the eligible applicant based on a proxy amount for the heat/electric costs. For non-heating electric costs, the applicant is eligible for a PB only if the vendor providing electricity to this dwelling is a participating PB vendor. • Do not pay. Energy included in the monthly rent when residing in government-assisted housing, renters who pay neither rent nor heating/electric costs because of an in-kind rental

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87 Revised: August 2025 arrangement, or renters who do not have a direct pay relationship and do not make any payment toward the energy cost(s) per the lease/rental agreement. This choice will result in no benefit being provided to the applicant, because they do not have an energy burden.

Applicants are required to provide verification for the following payment methods and the means of verification must be indicated in HE+ System Notes: • Heat and/or non-heating electric included in rent • Separate payment is made to the landlord, mobile home park owner, or no direct account with vendor • Do not pay

Verification may include, but is not limited to: • Observation of a lease or rental agreement • Observation of utility allowance on Form 50058 or Form 50059 • Verbal or written contact with the landlord • In some cases, the heating vendor can verify if heat is included

NOTE: Observation of previous years’ information is no longer an acceptable form of verification. New verification must be obtained.

NOTE: For multi-unit buildings, the agency may obtain information from the landlord/management company verifying that all units have heat and/or electric included in rent, a separate payment is made to landlord, or are do not pay. This verification may be used for all units within the building and must be obtained on an annual basis. The means of verification must be indicated in HE+ System Notes.

4.4.28.5 Vendor Information WHEAP workers can view vendor information by accessing the “WHEAP Vendor Details” Report. Enter either the vendor name or number in the “Vendor” search criteria and select the desired vendor(s).

You may enter the first few letters of the vendor name or the first few numbers of the vendor number. This will pull up all active vendors that match the criteria.

All vendors are “Direct Vendors,” and an applicant's benefit will be sent directly to their designated vendor. If an applicant is using a vendor who is not currently registered with the program, the agency must register the supplier, assist the applicant with locating a registered vendor, or arrange for an alternate payment method.

4.4.28.6 Account Number Enter the account number from the applicant's fuel bill. You must enter information into this field when payment method is “Directly pay the bill from the energy fuel supplier.” The account number entered must have a service address that matches the residence address of the household.

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Revised: August 2025 Account numbers are important as they are the primary identifier the vendor uses to post benefits to an applicant’s account. 1. If the vendor uses account numbers and the applicant or vendor cannot provide the number, leave the account number blank and leave the application “Pending” until the numbers are provided. The case will be denied if the information is not provided within 30 days.

Some vendors have a required account number format to be used when entering account numbers; this format will appear once the vendor has been selected. The vendor’s format must be used. 2. If the vendor does not use account numbers, enter “none.” 3. If the vendor uses the account name as the account number, enter the account name.

4.4.28.7 Annual Fuel Cost The HE+ System will not accept a fuel cost over $7,000. The worker shall enter $7,000 as the annual cost and indicate in HE+ System Notes when they receive the HE+ System prompt that costs cannot exceed $7,000. HE+ System Notes shall indicate what may be the cause of the high fuel costs. 1. Actual fuel costs are preferred. Any actual fuel costs available from the last 12-month time period from the date of application or from the prior heating season should be entered as the annual fuel usage. When a full 12 months of usage is not available, HE+ System Notes shall indicate how many months of usage this covers and why 12 months of usage is not available.

NOTE: If the customer recently moved to the address listed on the application, ask the energy provider for prior usage costs for the residence address. Prior costs shall be used for actual fuel costs.

When entering the actual fuel costs for a duplex, it is important to correctly note if there is a shared furnace/electrical meter as this will determine if the actual fuel cost or zero is entered for the annual costs to calculate the benefit. HE+ System Notes shall include the annual energy cost when the duplex has a shared meter situation.

When an applicant has used more than one vendor for deliverable fuel, costs from all deliverable vendors shall be added together to obtain the annual fuel cost when the applicant is able to provide receipts or obtain costs from each vendor. If cost information is not available from all vendors, enter the costs available and document in HE+ System Notes why this is not the full annual costs. 2. Annual budget amounts may be used when the complete prior 12 months or last year’s heating season usage is not available. Remember to convert any monthly budget amount to an annual amount by multiplying by 12.

NOTE: An applicant’s monthly payment cannot be used as a budgeted amount; budget must be provided by the vendor.

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89 Revised: August 2025 3. Enter "0" when the fuel costs available are not accurate or the budget amounts for utility fuels are not available and document in HE+ System Notes why “0” was entered. This does not mean there are no fuel costs, but rather that no information was provided. Benefit(s) will be calculated by using information taken from the proxy table of average costs for the type of dwelling and fuel (proxy fuel costs).

Enter "0" for the cost in the following situations: a. When actual costs, including budget amounts, are not available. b. If there is unusual and/or recreational energy use on the account that causes an impact on the annual energy costs. The System Notes shall include what the unusual and/or recreational energy use is and include the amount of the actual energy costs. c. When the energy costs are shared with another unit(s) in the building that are not a business and when usage is shared with another dwelling by extension cord. HE+ System Notes shall be added explaining the shared meter situation and include the annual energy cost.

The WEFI web service is a data validation function used to confirm direct pay electric or natural gas account numbers for the IOUs, which include Alliant, MG&E, Xcel, WPS, We Energies, and most of the WPPI member utilities. Review the data returned by WEFI web service for accuracy prior to adopting the cost data into the fuel page. WEFI web service will return all available cost and consumption data for the application address prior to the application date if the account is active on the day of the web service call. If more than 13 months of WEFI results are displayed, please use data from the online vendor portal or information given from the vendor and complete a manual entry for the annual costs. WEFI results may also include the date service was opened and current balance, depending upon the results available from each utility. WEFI web service will not provide cost or consumption data for closed accounts. For a closed account, obtain the annual costs from the utility and manually enter the cost data if the reason for a closed account is known.

Any discrepancies between the WEFI results and the information entered on the application shall be reviewed with the applicant and the results documented in HE+ System Notes.

4.4.28.8 Account Name and Household Relationship If the person whose name is on the account is a non-household member, select whether the person is a deceased spouse, protective payee, or “Other.”

If selecting “Other,” the relationship of the individual may be entered directly into the HE+ System “Account Name” field after the account holder’s full name or an HE+ System Note shall be added to state the relationship of this individual to the household.

If the account is not current or active because it has been closed, the agency needs to assist in getting a current account established. • If the account is closed because the applicant has moved, the application will be incomplete until a relationship can be established.

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Revised: August 2025 • If the account is closed because the applicant is not current with their payments and the applicant has not moved or otherwise changed vendors, the agency can use the closed account information on the application until current account information can be obtained.

4.4.28.9 Enter Name on the Account If the person whose name is on the account is a household member, select the name from the drop-down list. If the name on the account is a deceased spouse, a protective payee, or “Other” (non-household member), select the matching option from the list and then enter the name in the space provided.

If selecting “Other” (non-household member), the relationship of the individual may be entered directly into the HE+ System “Account Name” field after the account holder’s full name, or an HE+ System Note shall be added to state the relationship of this individual to the household.

4.4.28.10 Shared Meter If there is more than one unit on the meter and it is not operating as a business, enter $0 for the annual fuel costs of the associated account. Add detailed HE+ System Notes to explain there is a shared meter for a duplex or what is shared with the meter that is causing an unusual and/or recreational impact on the energy account and include the amount of the actual energy cost.

If the building(s)/dwellings(s) that shares the applicant’s household’s meter has low or no usage, or the situation is unclear, contact the HE+ Help Desk for additional guidance.

NOTE: If there is more than one unit on the meter and one of them is considered a business, select “Yes” for business use and add an HE+ System Note stating what type of business is on the same meter. Although the applicant may not directly operate or own the business, because their costs are recorded on one meter, business use on the meter still applies. Examples of business use include an applicant living in a home on the same property as an operating farm or in an apartment above an operating business. Residential rental property is not considered a business for business use purposes; enter $0 for the annual fuel costs if a landlord shares a meter with their tenant and include these details in HE+ System Notes.

In both situations, the applicant will receive a benefit based on a proxy amount for the heat/electric costs.

4.4.28.11 Business Use on the Account Use the following tests to determine if there is business use on the account: 1. Does the business occur in the home or other areas on the property where business usage is recorded on one meter? If so and the business activity likely has an impact on the home energy use, select “Yes” for business use on the account.

NOTE: If the business that primarily occurs in the home has little impact on the home energy use, select “No” for business use on the account and document this in HE+ System Notes. Examples would be occasional babysitting, working from home for a job that would

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91 Revised: August 2025 otherwise take place in the employer’s office, or producing crafts/homemade goods for sale without the use of equipment that increases the home’s energy use.

NOTE: Business use on the account is to be marked “No” if self-employment business is no longer in operation or currently inactive based on application test period.

If no, continue to #2. 2. Does the applicant see customers in their home or are there other areas on the property that operate as a business either by the applicant or the landlord? If so, select “Yes” for business use on the account. If no, continue to #3. 3. If self-employment income is operated entirely in a separate location or has very little activity in the home or other areas on the property, and fails the previous two tests, select “No” for business use on the account in the Energy Usage section of the HE+ Application; the actual fuel usage is used to calculate the benefit. Examples of self-employment income which generally have very little activity in the home are: cleaning services, home party sales, lawn care, snow removal, rental, construction, carpentry, and scrapping metal. 4. If the situation is questionable, indicate in HE+ System Notes the answers the applicant provided to the aforementioned tests. If you have a different situation or you are uncertain if there is business use on the meter, please contact the HE+ Help Desk for assistance in determining if there is business use.

In the case of an applicant living on a property that includes an operating farm, see Section 4.4.28.10 to determine the meter type.

An HE+ System Note shall be added describing the source of the income (self-employment or otherwise) and what test was used to determine business use or no business use on the meters.

NOTE: See Section 4.4.17 for information on counting the number of rooms.

4.4.28.12 Non-Heating Energy Costs Use the same procedures as for the primary heat source, using the actual vendor number for non- heating electric vendor.

Households without an electric burden must have documentation in the HE+ System Notes. Specify why an electric burden does not exist for the household; this includes households that do not have electric service.

4.4.28.13 Additional Energy Questions The additional energy questions are required for an application to be complete. The answers to these questions have no effect on the potential benefit amount.

4.4.29 Applicant Signature Date Enter the most current date the applicant signed the Certification Page. The date the applicant puts on the Certification Page is the date that should be entered. If the Certification Page is received with a signature, but no date, use the date the application/Certification Page was received as the

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93 Revised: August 2025 Chapter 5 | Crisis Assistance 5.1 Introduction Applicants are not entitled to Crisis Assistance benefits. Crisis Assistance is intended to provide emergency and/or Prevention Assistance services to assist applicants with substantial home energy needs. Most Wisconsin customers are protected by the winter moratorium state statute 113.0304 (2)(a) from November 1 through April 15. Most vendors are unable to disconnect customers for nonpayment during the winter moratorium.

Crisis policy is fluid and may change during the program year based on funding and customer needs. Policy shall be updated via Informational Transmittals (IT) during the program year. ITs are posted to the HE+ TTA website and are available to all WHEAP staff. Agencies are required to follow the most current Crisis Assistance policy.

1. Each local agency shall respond within 48 hours of the request for crisis assistance, and within 18 hours when there is a potential urgent safety concern. If the service date entered in the HE+ System is beyond 48 hours from the request date, an HE+ System Note shall be added to state when the customer was contacted after the request to address the crisis situation.

NOTE: Responding within 48/18 hours is a LIHEAP Statute and Regulation section 2604 (1). 2. Each local agency shall grant the amount identified by the vendor needed for the customer to prevent and/or restore an energy loss and not automatically issue the maximum threshold amount. See Section 5.2.1.2 for more information. 3. Benefits for LIHEAP and PB crisis and assistance are paid from a central account managed by the Division. 4. Crisis and assistance benefits are paid only to providers of goods or services. There is no reimbursement for action taken or expenses incurred by vendors prior to approval by the local WHEAP agency. 5. All Crisis Assistance payments must be completed by the last extraction of the program year (September 30). Crisis Assistance applications/payments not completed by the last extraction will deny. 6. Minimum Crisis Assistance payments shall be $100. All Crisis Assistance payments shall be rounded down or up to the nearest dollar. No cents may be entered for Crisis Assistance payments. 7. Agencies shall not exceed two (2) crisis payments per program year. Agencies may not grant exceptions to the 2 crisis payments per program year without HE+ Help Desk approval. 8. Agencies shall require customers to provide verification of their “no heat/energy” situation and/or energy-related problem before providing Crisis Assistance. 9. Agencies shall upload the verification of the energy crisis situation and/or Division Crisis Verification form into the HE+ System prior to issuing Crisis Assistance payments.

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Revised: August 2025 10. Applicants’ applications processed as zero costs due to a business or shared meter situation require approval from the HE+ Help Desk prior to issuing Crisis Assistance. Requests for crisis shall include a summary of the customer payment history. 11. Agencies shall not implement additional eligibility guidelines, Crisis Plans, and/or spending thresholds that deviate from Section 5.2.1.2 without approval from the Division.

5.2 Crisis Assistance Eligibility 5.2.1 General Eligibility Guidelines To be eligible for any Crisis Assistance, households must: 1. Meet the WHEAP eligibility criteria, and 2. Have a direct pay relationship with a participating energy vendor. Applicants without a direct pay relationship are not eligible for Crisis Assistance benefits.

To be considered for Crisis Assistance, applicants must have had eligibility determined by having completed an HE+ Application at any time during the current program year. If an applicant is deemed eligible for the current program year, the eligibility applies for the entire program year for Crisis Assistance services.

If an HE+ Application denies as over-income, there is no income eligibility exception for Crisis Assistance. If the household is over-income based on the prior month test period and there has been a change in the household’s financial circumstances, the HE+ Application may be processed using the present month income as described in Section 3.3.2. If the household is financially eligible based on the present month income, they are eligible for Crisis Assistance or HE+ Program Services. If the household’s financial circumstances have changed and there is an existing application from earlier in the program year that denied as over-income, a new HE+ Application shall be processed to determine current financial eligibility.

For applicants who have not applied during the heating season, eligibility must be determined by completing an application. The applicant will be denied a heating and/or an electric benefit because it is outside the program dates, but the applicant may be eligible for Crisis Assistance if the applicant is otherwise eligible for energy assistance.

5.2.1.1 Denial of Crisis Assistance Benefits or Services Eligible households may be denied Crisis Assistance because of: • The weather • Assets of the household • Failure to make payments on their energy bills • Having previously received Crisis Assistance twice during the program year • Having received $1,200 total in Crisis Assistance* • The applicant’s situation not being an emergency

*Agencies may submit a waiver request to the HE+ Help Desk to exceed $1,200 in crisis benefits or more than two WHEAP crisis benefit payments per program year.

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95 Revised: August 2025 If the household is ineligible for Crisis Assistance, the agency must notify the customer of the denial within 48 hours of the request for Crisis Assistance. An HE+ System Note must be created to state that the customer requested Crisis Assistance and was denied, with an explanation for the denial.

5.2.1.2 Crisis Assistance Amount Agencies shall work with customers and energy providers to determine the amount needed to prevent and/or restore an energy loss. Workers shall use the appropriate funding code/Service Type (LIHEAP for heating and PB for non-heating electric). If using a LIHEAP Service Type for the non-heating electric account, System Notes shall include the reason the LIHEAP Service Type was used. The maximum amount allowed for deliverable fuel requests is the minimum fill plus trip charge (when applicable). The maximum amount for natural gas and electric requests is the utility’s required down payment to prevent a disconnection and/or restore service. The worker must document, in HE+ System Notes, the requirement for each crisis request. If an exception is needed to the benefit limit, submit a request for an exception to the Division via the HE+ Help Desk. The request shall include the hardship the household is experiencing. Agencies shall not automatically issue the maximum threshold amounts. The amount issued should coincide with the amount listed on the customer’s energy crisis verification.

5.2.2 Crisis Eligibility − Additional Guidelines To qualify for Crisis Assistance, the household must have no heat and/or be facing an imminent loss of essential home energy and/or the household must have energy costs beyond their ability to pay after the Regular WHEAP Benefits. Each local agency has latitude in the type of assistance to provide and the amount of assistance to provide within the current crisis guidelines to address the crisis.

A brief summary provided in the HE+ System crisis application “Customer Request Reason” or an HE+ System Note is required to identify the reason for the Crisis Assistance. Agencies must contact the customer to verify they are still residing in the home and to verify with the vendor that the account is active, account balance, and that customers have met their customer contribution. The household contribution may come from another assistance program (such as Local Donation, Salvation Army, Catholic Charities, etc.). Agencies may not utilize funds from Utility Allowance and/or KWW/CF to pay the $25 contribution without an HE+ Help Desk approval. Crisis initiatives shall not be issued to accounts that have substantial credit balances.

Households must have paid at least $25 on their associated energy bill in the previous three (3) months from date of request to be eligible for any heating or non-heating electric related Crisis Assistance payment on the associated bill. This contribution may be from a non-WHEAP assistance program.

A household may be eligible for Crisis Assistance if their application for Regular WHEAP Benefits is denied solely for any of the following reasons: • The application for energy assistance was submitted outside of the program dates for heating assistance

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Revised: August 2025 • The application was found ineligible for Regular WHEAP Benefits only because a household member was a paid case head in another WHEAP household during the current heating season • The application contains denial of Regular WHEAP Benefits because benefits were already received in the current heating season

If the HE+ Application is waiting for SSN verification from SSA but is otherwise complete, Emergency Crisis Assistance may be issued by requesting a crisis override that is associated with a “Pending” or “On-Hold” application. This should only be requested for households experiencing actual or imminent loss of essential home energy during the heating season. The worker shall notify the applicant that they are responsible for repayment if any SSN on the HE+ Application cannot be verified (resulting in the application being incomplete).

5.2.2.1 Cooling Eligibility − Emergency Crisis Emergency services for cooling are provided during the summer months only in cases of extreme heat, with a declaration of a heat emergency, and approval from the Division. Agencies may not implement cooling assistance unless a state or local public health official declares a heat emergency and authorization is given from the Division.

5.2.3 Exceptions to the Applicant Contribution Requirement The Division may grant a special exception to the minimum requirement for an applicant to have paid $25 in the previous three (3) months from the request date to receive Crisis Assistance.

HE+ System Notes must be entered to describe the circumstances to justify granting the exception to the household. This should include attempts to request assistance from non-WHEAP funding to satisfy the client’s contribution. Agencies may not grant exceptions to the $25 payment contribution without HE+ Help Desk approval.

5.2.4 General WHEAP Agency Responsibilities 1. The WHEAP agency must conduct outreach and public information activities to ensure people are aware of the program and of how to obtain assistance. 2. The local WHEAP agency must establish a way for emergencies to be reported outside of office hours. This may be a telephone number currently in existence. For numbers outside the WHEAP agency (sheriff, 911, etc.), there must be written procedures for coordination between the WHEAP agency and the other resource. These procedures must include methods for information collection and follow-up procedures that are agreed to by all parties. This number must be published and available to applicants throughout the service area. 3. The WHEAP agency must identify a person(s) within the agency to assess referrals from fuel suppliers, utility Early Identification Programs (EIP), state or county Weatherization operators, and/or other local agencies. 4. The WHEAP agency shall develop agreements with local fuel suppliers. This includes wood dealers, and other vendors supplying energy-related services. The agreements must ensure a response to fuel emergencies, including those that occur outside of office hours.

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97 Revised: August 2025 5. The WHEAP agency must establish agreements with non-regulated utilities and deliverable fuel dealers (that are registered WHEAP fuel vendors serving households in the agency's area) to notify the WHEAP Coordinator or other designated staff person of all households who have been refused delivery. 6. The WHEAP agency must establish a method for the utilities, delivered fuel vendors, and heating contractors to easily report fuel emergencies. 7. The WHEAP agency must establish a method to follow up on utility disconnects during the heating season. Agencies must have agreements with local regulated utilities regarding procedures to be followed in the event of an actual disconnect. 8. The WHEAP agency must establish procedures with the Weatherization agency to ensure response within 72 hours for heating unit emergencies.

5.2.5 Emergency Crisis Situation When the agency is notified (either by an applicant or by another party) that a household has no heat or is facing the imminent loss of essential home energy, the agency shall determine whether there is a health and safety concern. The agency shall also determine whether the circumstances are life threatening in assessing what measures to take. 1. The response must protect the urgent safety concern(s) of the household members and alleviate the emergency. After the emergency is dealt with, agencies should assess an applicant's situation by using preventive services to continue to work with applicants to avoid future crisis situations.

Agencies should include the following criteria in their determination of action(s). Keep in mind the relationship of each factor with the other three. a. Expected low temperature during the period before the next working day b. Condition of the dwelling unit (i.e., is it habitable, is the furnace operable, mobile home, apartment, etc.) c. Alternatives available to the household (i.e., temporary relocation, other resources, etc.) 2. Agencies must determine the most appropriate and cost-effective solution to the emergency. Agencies must include in their array of services the following benefits for emergency services: a. Provision of the minimum benefit amount needed to address the immediate emergency, or b. Provision of temporary shelter for households experiencing emergencies

Examples of how to address an emergency include: a. A telephone call to the heating or electric supplier to guarantee a payment b. Relocation of the household (temporary or permanent) c. Repairing or replacing the heating unit, when appropriate through HE+ Program Services (see HE+ Program Services Manual)

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Revised: August 2025 d. Any other action or combination of actions that will at least address the emergency and protect the safety of the applicant (provision of blankets or temporary use of space heaters) e. Agencies may pay a portion of a household's non-heating electric bill using LIHEAP or PB funds for customers of participating vendors i. If a customer is eligible for LIHEAP, but not eligible for PB because their electric vendor does not participate in the PB program, the customer may receive LIHEAP Crisis Assistance for their non-heating electric service. ii. If a customer is eligible for PB, the customer may receive LIHEAP Crisis Assistance even if the household is not LIHEAP eligible. 3. If the heating system is not working, agencies may address this problem through HE+ Program Services. Repairs or replacements are only allowed to be done on the heating unit using the primary fuel type reported on the HE+ Application. If the customer’s water heater is leaking or otherwise not operating properly, or they have a leaky faucet, toilet, or other fixture, agencies may refer the household to the HE+ Water Conservation Program. For more information about HE+ HVAC Heating Program Services and HE+ Water Conservation Program Services, see the HE+ Program Services Manual.

5.3 Crisis Assistance Applications Remember the following items when entering Crisis Assistance applications in the HE+ System: 1. Review the data brought forward from the application. Correct any information that has changed from the original application. 2. Select the appropriate service types. 3. Respond accurately to the Performance Measurements questions on the application 4. The Request Date is the date the customer requested assistance, and the Service Date is the date the agency responded to the Crisis Assistance request. 5. For the vendor entry, any applicants with an account with an IOU, which includes Alliant, MG&E, Xcel, WPS, and We Energies and most applicants whose utility is a member of a WPPI utility, are subject to a WEFI web services call to confirm the account status. Use of the WEFI web service is required on all Crisis Assistance applications with IOU accounts.

The WEFI web service is a data validation function used to confirm direct pay electric or natural gas IOU account numbers. Review the data returned by the WEFI web service for accuracy prior to accepting the results of the call. Any discrepancies between WEFI results and information entered on the application shall be reviewed with the applicant and the results documented in HE+ System Notes. 6. When paying Crisis Assistance on a closed account, the HE+ System provides a field for entering notes. The worker shall document in this note section why Crisis Assistance is being paid on a closed account and have coordinated this, in advance, with the vendor. 7. Verify that the account name and account number is accurate and current. 8. Explain the circumstances of the crisis and how the crisis service will assist the customer in an HE+ System Note or in the “Customer Request Reason” field.

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99 Revised: August 2025 9. Enter an HE+ System Note to state how the $25 payment contribution was verified. 10. Agencies shall upload the verification and/or the Division Crisis Verification form of the energy crisis into the HE+ System prior to issuing Crisis Assistance payments.

NOTE: “Pending” and “On-hold” crisis applications must be submitted and/or denied within 30 days of the crisis application date.

5.4 Service Types 5.4.1 LIHEAP-Funded Service Types LIHEAP service type payments are made by the HE+ System using LIHEAP benefit funds. All these service types require entry of account number, account name, amount, and vendor number.

PEAS – LIHEAP Emergency Payment Emergency Crisis Assistance payment to a fuel supplier resulting in the delivery of fuel or a continuation of utility service.

PPAS – LIHEAP Assistance Payment Prevention Assistance payment sent to fuel suppliers/utilities. Payment may also be sent to a vendor for repairing or replacing fuel oil and LP tanks and/or lines.

SPSF – Summer Fill Payment Prevention Assistance code used specifically for a Division-directed Summer Fill Program and only available during specified program dates.

5.4.2 Public Benefit Funded Service Types Service types beginning with the letters “PB” indicate a PB Assistance payment made by the HE+ System using PB funds. The household’s electric vendor must be participating in the PB program. All these service types require entry of account number, account name, amount, and vendor number.

PBAS – Public Benefit Electric Payment PB Assistance payment to a PB electric supplier.

PBES – Public Benefit Emergency Electric Payment PB Emergency Crisis Assistance payment to a PB electric supplier resulting in restoring electric service or continuation of electric service.

5.4.3 HE+ Program Services Codes HE+ Program Services payments come from two separate central funds to pay all HVAC heating and water conservation activities throughout the state. See the HE+ Program Services Manual for information on eligibility, allowable activities, and other requirements for HVAC heating and water conservation services.

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101 Revised: August 2025 Chapter 6 | Quality Assurance The Division conducts a sample review of WHEAP agencies’ internal QA reviews uploaded in the HE+ System. The sample testing is to ensure compliance with WHEAP policy. If necessary, the Division may expand the sample testing if the initial review does not align with WHEAP policy or if program integrity concerns are discovered.

6.1 Quality Assurance Each contracted agency is responsible for participating in Division-conducted and internal quality assurance activities. All agencies will have an overall assessment of program operations at a fixed point in time of each program year. Such activities include, and are not limited to: • DTM • GQA • PSQA • VDTM

6.2 Desktop Monitoring Agency Responsibilities The contracted agency is responsible for participating in Division-conducted DTM quality assurance activities. This review is a means to ensure that agencies are correctly interpreting and applying WHEAP requirements and policies.

DTM reviews focus on these key program areas: • Program Operations • Program Integrity • General and HE+ HVAC Heating Program Case Review*

WHEAP agencies are required to: • Respond to all agency-required case corrections within the timeframes established by Division staff • Implement training at the local level based on DTM observations and Division staff recommendations and/or make agency staff available for training as directed by Division staff • Submit the pre-visit questionnaire by the deadline established by Division staff • Submit documents requested by the Division by the deadline established by Division staff • Attend scheduled T&TA Sessions led by Division staff • Ensure that all individuals whose attendance has been requested by Division staff are present at the specified times as determined by the Division

*Desktop Review application corrections that result in a cancel/refund require the associated Division Monitor to be contacted.

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Revised: August 2025 6.3 General Quality Assurance Agency Responsibilities The contracted agency is responsible for participating in internal GQA activities. GQA practices are intended to review the accuracy of current program year general cases. This internal quality assurance review is a means to ensure that WHEAP workers are correctly interpreting and applying WHEAP requirements and policies. In addition, results should be used to identify areas that should be used for internal training purposes. Local WHEAP agencies shall develop and implement a GQA Plan for general cases. The WHEAP agency shall maintain a file with a copy of the plan and the results of the internal review. The written plan shall include procedures for GQA review including: 1. Staff responsible for case review* 2. How cases are selected for review** 3. How often reviews occur during the program year

*The local WHEAP agency worker(s) who processed and/or verified the information on the general application under review shall not conduct quality reviews of the general application. **Cases selected for the agency internal GQA review must be different from those selected for HE+ PSQA review.

Agencies are required to sample a variety of cases from multiple workers, if possible, when conducting the review.

Using the Division’s GQA tool, WHEAP agencies shall complete their required internal GQA review no later than January 31 of each program year. WHEAP agencies shall upload their completed internal GQA review to their current WHEAP contract in the HE+ System within 3 business days of the January 31 deadline. An agency's paid WHEAP caseload for the prior program year shall determine the number of cases selected for review: • Agencies with a prior year caseload of 5,000 or greater shall select 20 general cases and 10 crisis applications as identified by the agency from the current program year • Agencies with a prior year caseload of fewer than 5,000 shall select 10 general cases and five (5) crisis applications as identified by the agency from the current program year

*If an agency is unable to review the required number of cases, a note shall be added to the GQA tool to state this.

At the time of the review, the agency reviewer shall add an HE+ System Note to each general case, identifying it as having been reviewed.

6.4 Program Services Quality Assurance Agency Responsibilities The contracted agency is responsible for participating in internal PSQA activities. PSQA practices are intended to review accuracy of current program year HE+ HVAC Heating Program and HE+ Water Conservation Program Services referrals and cases. Local WHEAP agencies shall develop and implement a PSQA for HE+ HVAC Heating Program repair/replacements and HE+ Water Conservation Program Services activities. The WHEAP agency shall maintain a file with a copy of

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103 Revised: August 2025 the plan and the results of the internal review. The written plan shall include procedures for program services case quality assurance review including: 1. Staff responsible for case review* 2. How cases are selected for review** 3. How often reviews occur during the program year

*The local WHEAP agency worker who processed and/or verified the information associated with the HE+ HVAC Heating Program and/or HE+ Water Conservation Program Services application under review shall not conduct quality reviews of the selected application. **Cases selected for the agency internal PSQA review must be different from those selected for GQA review.

WHEAP agencies shall ensure the internal PSQA is conducted twice per program year: once by March 1 for October to February activity, and once by June 1 for March to May activity.

Each of the two rounds of reviews shall be conducted as follows: • Agencies with a prior year caseload of 5,000 or greater shall select: o 6 HE+ HVAC Program cases* o 3 HE+ Water Conservation Program Services cases* • Agencies with a prior year caseload of fewer than 5,000 shall select: o 2 HE+ HVAC cases* o 1 HE+ Water Conservation Program Services case*

*Contact the HE+ Help Desk if the required number of cases are not available by each deadline and add a note to the PSQA tool to state this.

1. The review shall also include the original or “parent” HE+ Application associated with HE+ Program Service(s) to ensure that eligibility and benefits were accurately determined. 2. WHEAP agencies shall upload each completed internal PSQA review to their current WHEAP contract in the HE+ System within 3 business days of the March 1 and June 1 deadline(s). 3. All agencies shall use the Division HE+ PSQA tool. 4. At the time of the review, the agency reviewer shall add an HE+ System Note to each HE+ Program Services case, identifying it as having been reviewed.

6.5 Vendor Desktop Monitoring Agency Responsibilities WHEAP vendors are responsible for participating in Division-conducted quality assurance activities at the Division's request. VDTMs focus on the fair pricing, delivery, and proper crediting practices of a specific vendor.

To assist in the process, WHEAP agencies are required to:

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105 Revised: August 2025 Chapter 7 | Errors, Mistakes, and Corrections 7.1 Updates to Applicant Information An HE+ System Note shall be included for all changes made to the application, along with how the information was learned and/or verified.

7.1.1 Change in Address Changes/corrections in addresses for applications that have been extracted should be recorded by adding HE+ System Notes in the following situations: 1. Moved out of county/tribe: If an applicant has moved out of your agency’s county/tribe. Note the change to the mailing address. 2. Moved into your agency’s county/tribe from another county/tribe: If an applicant has moved into your agency’s county/tribe. If crisis is being requested, update the address in the crisis application. 3. Moved prior to extraction: If an applicant moved prior to the extraction of the application, update the mailing address only in the application with the new address to ensure the benefit notice reaches the applicant. The application is valid based on the date of the application and must reflect the correct physical address and fuel account information. 4. Moved for Weatherization eligibility: If an HE+ eligible household moves, the Weatherization referral does not automatically carry to the new address. The household may re-apply during the same program year to determine eligibility for Weatherization Assistance at the new address by completing an HE+ Application through the local agency.

7.1.2 Own or Rent When processing an HE+ Program Services application, it is sometimes determined that the “Own or Rent” question was incorrectly entered on the original application or that the ownership status has changed. The HE+ System allows workers to change the response to the “Own or Rent” question on the HE+ Program Services application. However, the information completed on the HE+ Program Services application does not carry forward onto the next application. Therefore, the worker needs to enter an HE+ System Note to ensure the correct information is available for subsequent applications.

7.1.3 Fuel Switch If there was a fuel switch conducted when the furnace was replaced, workers should add a HE+ System Note with the new fuel type.

7.2 Benefit Calculator The benefit calculator allows for a quick calculation of possible benefit amounts.

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Revised: August 2025 The benefit calculator will provide a heat (LIHEAP) benefit amount and an electric (non-heating) PB amount. These are not final/actual benefit amounts as other factors can affect whether a household is eligible for a certain benefit. If a household is not eligible for an electric benefit (for example, because the utility is not participating in the PB program), the HE+ System benefit calculator will show what the benefit might have been if the household were eligible. Similarly, if a household is not eligible for a heating benefit (for example, because the family lives in subsidized housing with heat included in rent), the HE+ System benefit calculator will show what the benefit might have been if the household were eligible.

The benefit calculator should be used to determine if a benefit has been underpaid, or overpaid, by $100 or more. During program years that supplemental benefits have been issued by the Division, the $100 threshold must be based on the sum of the original and the supplemental benefit(s).

7.3 Regular Application Actions When correcting errors or mistakes, or dealing with updates because of additional information, review both heat and electric benefits even if the correction seems to be for only one benefit. Remember the HE+ System deals with each benefit separately.

7.3.1 Cancel Benefit (Cancel and Refund) Agencies are required to contact the HE+ Help Desk to request the Division process all cancel/ refunds. Agencies are required to process the replacement application with the corrected information while on the phone with the Division.

WHEAP agencies are required to add HE+ System Notes stating the error that was observed that results in the need for the cancel/refund.

It is possible to cancel one benefit (heat OR electric) or cancel an application by cancelling both benefits. The cancellation of the entire application is not conducted when only one benefit needs to be corrected.

Exception: When cancelling a benefit on an application where Fuel Usage Type is “BOTH,” both the heat and PB are cancelled even if only one of the benefits is affected by $100 or more.

NOTE: When requesting a cancel/refund, provide the following information via email to the Division for review or by using the Division-created cancel/refund worksheet found on the HE+ TTA website: error which caused the need for a cancel/refund, which benefit was affected by the needed correction, and all documentation.

7.3.2 Denied Incomplete If an application is denied as incomplete and not extracted, and the needed information is received before the case extracts, the additional information to the application shall be added to the application. Resubmit for benefits if the case is now completed; “save” if the case is still incomplete.

If a customer provides missing information for their current year application, the WHEAP agency may complete and submit their application even if more than 30 days have passed since the

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107 Revised: August 2025 original application date and the application has denied (extracted) as incomplete. Agencies are required to contact the customer before creating a new application to verify if the address, household composition, and income information remain valid. To reinstate an “Extracted” application, a worker creates a new application with the original application date, includes the additional information that was missing from the original application, and submits the new application. Add HE+ System Notes to explain the error. To avoid another denial for not being processed in 31 days, agencies shall ensure that all required verification documents are received prior to reinstatement so the new application can be created and submitted on the same day.

The original Certification Page may be used for the reinstated application. For more guidance see Section 4.4.29.

7.3.3 Updates to Unextracted Applications If an application needs to be updated and it is in an unextracted state, either “Paid” or “Denied” status, updates can be performed, and the application may be changed to “Pending” (saved) status or may be submitted for benefits. An HE+ System Note shall be added to identify why the application was changed to “Pending.”

7.3.4 Denied in Error and Extracted (Reinstate the Application) If an “Extracted” application denies one or both benefits in error, create a new application with the original application date. Include the additional or corrected information, then submit the new application. Add HE+ System Notes to explain the error (see Section 7.3.2 for more information).

Example: Information was received before the 31 days expired but it was not entered in the original application.

This is referred to as “Reinstating the Application,” and the original Certification Page is sufficient to consider this application complete.

7.3.5 Applications in “Paid” Status – “Extracted” State Do not cancel an “Extracted” application because an applicant wants to withdraw or because the applicant wants to reapply at a later date.

7.3.6 Error with an “Extracted” Application 7.3.6.1 Errors Which Do Not Affect the Benefit(s) There are many “errors” which do not affect the eligibility or benefits paid. For these types of errors, do not cancel the application. Errors of this type should be corrected with HE+ System Notes attached to the application with the wrong information documenting the error and the impact to the application so that the incorrect information is not carried forward to future applications.

Examples of these errors include: • Own or rent designation incorrectly identified (put the correct designation on the HE+ Program Services application, if appropriate) • Fuel account number is wrong

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Revised: August 2025 7.3.6.2 Errors Which May Affect the Eligibility/Benefit(s) There are many errors which have the potential to affect the eligibility/benefit amount(s). Due to multiple factors affecting eligibility and benefit amounts, each error and each case should be evaluated individually.

Some errors that may affect the benefit amount or household eligibility include: • Housing type • Number of rooms • Incorrect fuel type • Annual fuel use • Number of eligible household members • Income • Energy burden • Student status • Payments to the wrong vendor • Incorrect selection of categorical eligibility

If an error is discovered on an “Extracted” application which may affect the benefit or eligibility, the first step is to determine if the correction causes a change in payee, or a change of $100 or more in either the heat or PB (electric). Use the benefit calculator to determine the adjusted benefit. See Section 7.3 for important additional guidance. 1. If neither benefit is affected by $100 or more (increased or decreased), add an HE+ System Note to the application clarifying the correct information and benefit calculation results.

If the error is corrected income (type or values), note the correct income amount in HE+ System Notes associated with the original application.

If income calculation involves reviewing self-employment income documentation that was not included as a document upload with the original application, the additional documents shall be uploaded by using the upload function on the “Extracted” application as “Other WHEAP Documents” in the document slider.

If either or both benefit(s) is affected by $100 or more (increased or decreased), then corrective actions need to be taken. Agencies are required to contact the HE+ Help Desk to process a cancel and refund.

Always enter HE+ System Notes to explain why the application is being corrected. 2. If only one of the benefits is affected by $100 or more, the Division will cancel/refund the affected benefit only. Agencies are required to contact the HE+ Help Desk to process a cancel/refund. Enter the correct information on the replacement application at the time a of the cancel/refund. (The unchanged benefit will not pay because it has already been paid).

Exception: When cancelling a benefit on an application where Fuel Usage Type is

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109 Revised: August 2025 “BOTH,” both the heat and PB must be cancelled even if only one of the benefits is affected by more than $100.

If both benefits are affected by $100 or more, the Division conducts the cancel/refund of the application (by cancelling both benefits). Agencies are required to contact the HE+ Help Desk to process a cancel/refund. Enter the correct information on the replacement application. All other application information should be the same as the original application including date of application and fuel usage. Review the fuel usage from the WEFI call and if the usage is different than on the original WEFI call, enter the fuel usage from the original application as a manual fuel entry.

Document upload is required for replacement applications. Additional documents may also be uploaded to the replacement/corrected application if warranted. Documents uploaded to the original application may need to be downloaded from the initial application and then uploaded to the replacement application.

The Division will follow guidance below regarding when to select “vendor” or “client” for repayment. 3. When performing a cancel/refund for either or both benefits, the party responsible for the refund defaults to the vendor. Vendor shall be selected for refund responsibility unless directed in policy otherwise. 4. If the benefit with the error was issued as a single party check, the default and only option for refund responsibility is the client. 5. If the benefit with the error, entirely or in part, was paid to a deliverable fuel vendor (propane, fuel oil, wood), the benefit must be corrected. If the applicant has received the fuel, the local agency must proceed with the benefit correction. If the overpayment is due to an agency error, the Division selects vendor as responsible for the correction. To cover any shortage to the deliverable fuel vendor resulting from the correction the Division issues an “Additional Payment” for the difference.

NOTE: If an Additional Payment needs to be issued to the vendor to cover funds due, this should be done at the time the benefit is cancelled and refunded. The Additional Payment is processed on the application that has been cancelled and refunded so payment can be issued at the same time the cancelled benefit is processed.

If the correction can be made before the deliverable fuel dealer has delivered the fuel, the agency shall notify the vendor that benefits will be recaptured and contacts the Division to proceed with the correction with the vendor as responsible. The agency shall document in HE+ System Notes when the vendor was contacted and verified that there was sufficient credit balance to cover the overpayment.

In situations where it is not a result of an agency error, the Division selects the “Client” as responsible for the refund. 6. WHEAP agencies may be responsible for repayment of benefits issued if the cancellation of benefits was the result of agency error.

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Revised: August 2025 NOTE: The household shall not be held responsible for repayment in the above circumstances and WHEAP contract funds may not be used for these payments. 7. For all situations, LIHEAP Crisis Assistance shall not be issued to compensate for a reduction in regular WHEAP benefits due to a correction to an application. Crisis can be issued if the customer needs assistance with their energy costs.

Include in HE+ System Notes how it was determined who is responsible for paying back the overpayment and how the vendor was notified of this action. DO NOT instruct the vendor to refund any credit balance. When the benefit is cancelled, the payment is recaptured (offset) from future payments to the vendor.

7.3.6.3 Errors Which Affect Weatherization If an application is cancelled due to incorrect eligibility determination and no eligible replacement application is processed, the WHEAP agency shall notify the Weatherization agency if the weatherization status is “In Progress.” The situation must be fully documented in HE+ System Notes and local fraud procedures must be followed, when applicable.

If there is no current year application that is affected but fraud is discovered that affects eligibility for a prior year application that is dated within the last 12 months, the agency must contact the Weatherization agency as that application may be qualifying the applicant for Weatherization services that they are not eligible for.

7.3.7 Wrong Vendor Entered on Application Determine when the vendor changed. 1. If the applicant had changed a vendor prior to the application date, cancel the application for that benefit and process the corrected application. a. Cancelling the benefit will recapture the benefit from the incorrect vendor and processing the new application will send the benefit to the corrected vendor. Do not instruct the vendor to send the benefit to the correct vendor. 2. If the applicant changed vendors after the application was taken, see instructions in Chapter 8 regarding credit balances; the vendor should not return the money to the Division. An HE+ System Note must be entered to document the change in vendor.

7.3.8 Deceased Individual A user with the “Supervisor” permission can update an individual’s status as deceased. From the “Person Summary” for the deceased person, select “Update Status” from the Action Ribbon. Update the deceased status from the drop-down menu to “Yes.” Enter an HE+ System Note to indicate how the agency learned of this information including date of death.

The MCI database also identifies individuals who are deceased. When an SSN alert is received that an individual is deceased, the person status is updated to “Deceased” and a message is added to the “Person Summary” stating “Person Marked as “Deceased” by SSA and marked via the System. Date of death: MM/DD/YYYY.”

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111 Revised: August 2025 If an individual has been identified as deceased, in error, a user with “Supervisor” permission can update the status. HE+ System Notes should be added to document the change in status. The person status will be changed to “Not Processed” and will be validated through the MCI process on the next application.

If the death of the case head or household member occurs after the date of application and before the application is extracted, the application is no longer valid. The application will deny because there is a deceased individual on the application. “Submitted” applications change from “Submitted” status to “Pending-Pending.” The following message displays on the application, “At least 1 household member has been marked as deceased” and the SSN status of the individual is “Deceased.”

Any unextracted crisis or HE+ Program Services applications are systematically locked when the case head or household member has been marked deceased. The agency must contact the HE+ Help Desk to unlock the crisis or HE+ Program Services application and shall receive prior approval before processing the application. Prior to contacting the HE+ Help Desk to unlock the application, the agency shall take a new application to establish eligibility for the remaining household members. If eligibility is established with the new WHEAP application, the agency shall determine the crisis need. If Crisis Assistance is needed, DEHCR will unlock the crisis application for processing. If WHEAP eligibility cannot be established or if crisis is no longer needed, the crisis application will be unlocked and denied. For additional guidance, please contact the HE+ Help Desk.

NOTE: “Create Current Year Application” and “Create Early Application” is grayed out with the red circle and white minus sign indicating these functions are not available on the “Person Summary” of an individual who is identified as deceased. If a household member is marked deceased, the checkbox on the “Household Members” result list is not available for selection. Proceed with processing the application without the deceased household member and add HE+ System Notes that the individual was listed on the paper application, but now marked deceased. In addition, a case head whose status has been identified as “Deceased” will not be included in the Fixed Income report.

7.4 Automated Applications Local WHEAP agency staff are not expected to routinely review the automated applications. Local WHEAP agencies may learn of household circumstance changes (from returned mail or calls from a household member). Do not delete an “Automated Application.” The following sections describe the courses of action recommended when circumstances have changed in an automated application household.

7.4.1 Death of Case Head or Household Member When local WHEAP staff are informed of the death of the case head and/or household member, do not delete the application. 1. When the death of the case head and/or household member happens prior to extraction of the application: a. Navigate to the “Person Summary” of the deceased individual(s) to indicate that the

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Revised: August 2025 person is deceased. See Section 7.3.8 for further information on marking an individual as deceased in the HE+ System. b. Marking an individual as deceased changes the application status of any unextracted application to “Pending-Pending” status and the application will deny because there is a deceased individual on the application. c. The following message is displayed on the application: “At least 1 household member has been marked as deceased.” The SSN status of the individual is “Deceased.” d. The applicant household will be sent a denial letter when the associated application has been extracted. 2. If household member(s) remain: a. Local agency staff should encourage the remaining household members to apply with a new application. A new application date and new Certification Page is required for the application to be complete. Use WEFI to update annual energy costs. A new application cannot be entered into the HE+ System until the automated application extracts. A paper application process is recommended while awaiting the first extraction. b. If the deceased individual is a household member, a new application for the original case head and any other remaining household members is required.

7.4.2 Change in Household Composition or Income When there are changes in the number of household members or in the income counted for the household: 1. Make the corrections to the application (change the application status to “Pending,” update the information, and resubmit). Add HE+ System Notes to explain what was changed and why. 2. Obtain a signed Certification Page, if applicable, and upload to the HE+ System. 3. Do not change the application date or annual fuel costs. 4. Do not change the “Outreach Type” or “Is Interactive” field. 5. Do not delete the application.

7.4.3 Change in the Address (Moved) 1. If the household has moved and the new location is in the same county or tribe, the local agency must: a. Document in HE+ System Notes the reason the fuel account was active during the automated application process. b. Add HE+ System Notes to explain what household changes occurred, change the application status to “Pending,” and change the mailing address to the new address so the denial notice is sent to the correct location. c. Add HE+ System Notes to explain the situation. The applicant needs to reapply with the new address and household information. The new application cannot be entered in the HE+ System until the automated application extracts. A paper application can

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113 Revised: August 2025 be completed until the application can be entered. 2. If the move is to a different agency’s county or tribe, the agency with the original address takes the first two steps. The applicant must contact the new WHEAP agency serving the new address to complete a new application. a. Document in HE+ System Notes the reason the fuel account was active during the automated application process. b. Add HE+ System Notes to explain what household changes occurred, change the application status to “Pending,” and change the mailing address to the new address so the denial notice is sent to the correct location. c. Create a new (complete) application and add HE+ System Notes to explain the situation. The new application cannot be entered in the HE+ System until the automated application extracts. A paper application can be completed until the application can be entered. 3. If the move is to an assisted living facility, the local agency with jurisdiction of the application must: a. Document in HE+ System Notes the reason the fuel account was active during the automated application process. b. Add HE+ System Notes to explain what household changes occurred, change the application status to “Pending,” and change the mailing address to the new address so the denial notice is sent to the correct location.

7.5 Crisis Application Actions 7.5.1 Crisis Paid to a Vendor in Error If a crisis benefit is paid to a vendor in error, the agency shall use the following guidance:

Agencies are required to contact the HE+ Help Desk to process a cancel and refund.

If the crisis benefit with the error was paid to a deliverable fuel vendor (propane, fuel oil, wood), and the applicant has received the fuel, the Division selects the “Client” as responsible for paying the benefit back and the WHEAP agency shall contact the applicant to set up a repayment arrangement. See Section 8.9 for more information. 1. If the crisis benefit with the error was paid to a deliverable fuel vendor and the delivery has not yet been made, the Division selects “Vendor” as responsible for paying the benefit back. The WHEAP agency shall contact the vendor to advise the benefit was cancelled to ensure a future delivery is not made based on that benefit. 2. If the crisis benefit with the error was paid to a natural gas or electric vendor, the Division conducts a cancel/refund of the crisis benefit. 3. If a crisis benefit needs to be reissued because the original crisis was paid to the wrong vendor, a new crisis application can be entered if adequate crisis funds exist.

7.5.2 Crisis Paid to Wrong Account If a crisis benefit is paid to the correct vendor but wrong account name or number, the agency needs to:

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Revised: August 2025 1. Notify the vendor of the incorrect and correct account information 2. Request the benefits be transferred to the correct account name/number 3. Enter HE+ System Crisis Notes to indicate the date the request was made to transfer the benefits

7.5.3 Crisis Application When Application is Cancelled If the basic information for the crisis (address, vendor, fuel type) is unchanged, it is not necessary to cancel the crisis. Do not cancel the crisis unless conditions make it necessary.

7.5.4 Copayment Agreement Actions To cancel all remaining payments in a copayment plan without sending a denial letter to the applicant, delete each due date transaction that no longer needs to be paid.

7.6 HE+ HVAC Program Services Actions 7.6.1 Ownership Change If the ownership needs to be changed for a household because it was incorrectly entered on the regular application, information must be provided to show ownership or rental tenancy, and the worker must change the homeownership status on the HE+ Program Services application.

7.7 Incorrect HE+ HVAC Program Services or Weatherization Referrals WHEAP agencies may be responsible for repayment of HE+ Program Services (HE+ HVAC Heating Program or HE+ Water Conservation Program Services) or Weatherization services expenses if: • Homeownership is not verified in compliance with HE+ policy • HE+ HVAC Heating Program, HE+ Water Conservation Program Services, or Weatherization services are completed when the household’s HE+ program eligibility is not determined in compliance with HE+ policy • An HE+ Program Services referral was sent to the Weatherization agency when the HE+ Program Services application contains a denial reason (agencies shall “Save” the HE+ Program Services referral before marking it “Ready for Referral”)

The agency that did not follow policy guidelines may be held responsible for repayment of HE+ HVAC Heating Program, Water Conservation Program Services, or Weatherization services. If the WHEAP agency becomes aware that the above has occurred, the WHEAP agency must notify the Division and/or the Weatherization agency before any action is taken.

NOTE: The household shall not be held responsible for repayment in the above circumstances and WHEAP contract funds may not be used for these repayments.

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115 Revised: August 2025 Chapter 8 | Payment Adjustments, Refunds, and Returns 8.1 Basic WHEAP Payments Most WHEAP payments are issued directly to a vendor. For some Regular WHEAP Benefit cases a check is sent directly to the applicant.

8.2 Payments Sent Directly to the Vendor Regular WHEAP Benefit payments are sent directly to the applicant’s vendor (fuel supplier/utility). Crisis Assistance payments are sent directly to vendors supplying the crisis services. 1. In order for WHEAP to make payments to any business entity, the vendor must be registered with the State, have an assigned vendor number, and be designated as “active” in the HE+ System. Registered vendors must agree to comply with the policies outlined in the “Fuel Supplier/Vendor Agreement” and set forth their services and servicing requirements.

A vendor may be active for LIHEAP (heat), PB (non-heating electric), or both funding sources. If a vendor is not active for a funding source, it cannot receive a payment from that source. An example of a vendor only eligible for payments from one source is a utility not participating in PB; such a vendor may be eligible to receive LIHEAP payments and is not eligible to receive PB payments. 2. If a local WHEAP agency believes the fuel supplier, or vendor, is not adhering to its agreement, the local agency should notify the Division for investigation. If there is a violation of the agreement, the Division staff will work with the vendor to achieve compliance with the agreement or recommend to the Division Administrator that corrective action is taken, e.g., suspension of fuel supplier/vendor agreement.

8.3 Checks Sent Directly to the Applicant A single party check for Regular WHEAP Benefits will be sent to: • Recipients who have heat/electric included in their rent • Recipients who pay heating and/or electrical costs to the landlord or a mobile home park owner • Some recipients on master meters (see Chapter 3) • Recipients who purchase fuel from a non-registered WHEAP supplier/vendor

Crisis Assistance benefits are sent directly to a vendor on behalf of a recipient, not directly to a recipient.

8.4 Checks Sent to the Local WHEAP Agency When a local WHEAP agency enters its address for the applicant mailing address, the HE+ System sends single party checks for the Regular WHEAP Benefit directly to local agencies.

Checks are returned to the Division when a lost or stolen check is replaced or if the mail is returned via USPS for an invalid address as specified in Section 8.6.3.

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Revised: August 2025 8.5 Payment Registers For each extraction, one payment is sent to a vendor for all applicants who identified the vendor as their energy supplier, Crisis Assistance provider, or Weatherization agency that coordinated HE+ Program Services activity. WHEAP cases are extracted from the HE+ System on Wednesday evenings and checks are mailed the following Monday. Vendors paid by ACH receive their payments following the weekly extraction. Vendors must post payments to customer accounts within seven days from the date of the check. Due to federal holidays, occasional deviation from the extraction schedule is warranted. The extraction schedule for the full program year may be found via the Division website.

Prior to receipt of the payment, the vendor is provided a payment register on the HE+ System or via mail. The payment register includes account number, account name, applicant name, applicant address, county/tribe, benefit amount, and benefit type.

Vendors, local WHEAP agency staff, and State staff having specific security access can view check registers.

8.5.1 System Codes 1. Payment Codes – These codes regularly appear on the check registers. HTPAY Heat Paid – Regular heat (LIHEAP) benefit payment PBPAY PB Paid – Regular electric (PB) benefit payment CRPAY LIHEAP Crisis Paid – All types of LIHEAP crisis payments PCPAY PB Crisis Paid – All types of PB crisis payments FNPAY Furnace Paid – Payments for furnace services 2. Cancellation Codes CRCAN LIHEAP Crisis Cancellation PCCAN PB Crisis Cancellation FNCAN Furnace Services Cancellation HTCAN Heat Benefit Cancellation PBCAN Electric (PB) Benefit Cancellation 3. Reserved Payment Codes CRRES LIHEAP Crisis Reserved (SCCC) – LIHEAP funds reserved for future payment PCRES PB Crisis Reserved (SPBC) – PB funds reserved for future payment FNRES Furnace Reserved – Funds reserved for furnace services 4. Denied Payment Codes CRDENY LIHEAP Crisis Denied PCDENY PB Crisis Denied FNDENY Furnace Denied HTDENY Heat Denied PBDENY PB Denied

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117 Revised: August 2025 PHDENY Heat and PB Denied with a “General Denial” – Examples of a General Denial include “Your income exceeds the eligibility limit” and “The application date has exceeded 31 days.”

8.6 Check Returns When any check is sent to the Division, it must be accompanied by a memo identifying the applicant(s), the amount of the benefit(s), what the payment(s) was (regular, crisis, or HE+ Program Services benefit), and the reason(s) for the return.

Refunds, repayments, and written communications concerning payments should be addressed to:

DOA/DEHCR Attn: WHEAP Refund PO Box 7970 Madison, WI 53707-7970

Email communications should be addressed to heat@wisconsin.gov.

Checks should be made payable to DOA/DEHCR.

8.6.1 Recipient Returns When a single party heating/non-heating assistance check is returned to the local WHEAP agency, the agency shall provide the recipient with a receipt for the check. Send the check along with the check stub, if available, to DEHCR. DO NOT ENDORSE THE CHECK.

8.6.2 When a Notice is Returned by Post Office Notices are only returned when the post office does not have forwarding information for the applicant. When a benefit notice is returned by the post office, do not discard the returned notice before checking on the reason for the return.

Try to determine the applicant’s correct mailing address, correct any discovered errors, enter an HE+ System Note, and if an address was established, resend the notice.

Returned mail should raise a caution flag about an applicant’s situation and be investigated for application data accuracy.

8.6.3 When a Single Party Check is Returned by the Post Office Single party checks are returned to the Division whether or not forwarding information is available. Upon the return of a Single Party Check, the Division will send an email to the WHEAP agency that processed the application and request the following steps be taken: 1. If the returned check includes a new address: a. Contact the applicant to verify the address b. Check to see if there are related changes in the case record (house type, number of rooms, fuel type, etc.)

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Revised: August 2025 c. Add an HE+ System Note d. Provide response on findings to the Division 2. If the returned check does not indicate a new address/forwarding address: a. Try to locate the application to verify the address b. If the applicant cannot be located after 30 days, notify the Division that the applicant could not be located c. Add an HE+ System Note

8.6.4 When a Supplemental Benefit is Returned 1. Single party supplemental benefit checks returned by USPS shall be processed as specified in Section 8.6.3. 2. Vendors will often return applicant supplemental benefits when an applicant moves and does not provide the vendor with a forwarding address. If an applicant subsequently contacts the agency to claim the payment, contact the HE+ Help Desk.

8.6.5 Returned Because the Applicant Is Deceased If an applicant is deceased (after the application date), the check should be used to pay outstanding energy bills, and the remaining balance must be returned to the Division when the account is closed. DO NOT ENDORSE THE CHECK. Navigate to the “Person Summary” in the HE+ System to indicate that the person is deceased.

8.6.6 Vendor Identified Incorrect Payments All suppliers are required to review the weekly WHEAP payment register for accuracy of home energy assistance and Crisis Assistance payments. In the event a payment is made to a supplier in error, the vendor should contact the local agency (listed on the payment register) within 30 days to correct the error. 1. Payments of Regular WHEAP Benefits made in error must be corrected by the local WHEAP agency and will be refunded/recaptured through the next regular WHEAP home energy assistance payment(s) made to the supplier. Vendors should not prepare and send a check to the Division in these situations unless requested by Division staff. 2. In the event a Crisis Assistance payment is made to a supplier in error, the local WHEAP agency must: a. Cancel/refund the crisis payment b. Notify the vendor of the error c. Inform the applicant about the change in benefit

Vendors should not prepare and send a check to the Division in these situations unless requested by Division staff, as the benefit will be offset by a subsequent regular “Heat” and/or PB paid (HTPAY/PBPAY).

8.7 Refunds Vendors must notify the local WHEAP agency of any refunds.

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119 Revised: August 2025 Refunds may be for one or more customers. Each customer needs to be identified if multiple customers’ refunds are on one single check. The amount returned needs to be identified per customer.

When it is appropriate to return funds to the Division, checks should be made payable to DOA/ DEHCR, and the following information should be provided: 1. Customer/applicant’s name 2. Customer/applicant’s address 3. Name of agency where customer applied for WHEAP 4. Date of energy assistance (or heating season) benefit 5. Reason for the return of funds (such as moved and unable to contact, deceased, or moved but new vendor does not participate in the PB program) 6. Type of funds returned (such as LIHEAP Heat Benefit, LIHEAP Crisis Benefit, PB Electric Benefit, PB Crisis Benefit, or HE+ Program Services Benefit) 7. Amount of funds being returned

8.7.1 Regular WHEAP Benefits Regular WHEAP Benefit payments made to a fuel supplier shall be applied to the current heating season costs. WHEAP payments that exceed current heating season costs must be applied as a credit to the customer’s account. Supplemental payments are considered part of the original WHEAP benefit. 1. If a recipient retains the same supplier with an active account, the credit balance remains with the supplier until exhausted. 2. If the account becomes inactive, a reasonable effort must be made to contact the applicant and/or the local WHEAP agency to identify the new fuel provider to transfer the credit to the new supplier. Exception: PB non-heating assistance (electric) is not transferable to a vendor who does not participate in the PB program. If the vendor does not participate, the funds should be refunded to the Division. 3. If a new fuel provider cannot be identified, the funds should be transferred to the customer/applicant. Exception: PB non-heating assistance (electric) is not transferrable to an applicant whose vendor does not participate in the PB program. If an applicant’s vendor does not participate, the funds should be returned to the Division. 4. If the customer/applicant cannot be located, the funds should be refunded to the Division. 5. If the customer/applicant moves out of the state, any LIHEAP heat benefit is to be transferred by cash or check to the customer/applicant. All PB (electric) assistance balances are to be refunded to the Division. 6. If a credit balance remains for a deceased applicant and the account is closed, the balance must be refunded to the Division no later than the end of the program year (September 30). 7. When a WHEAP recipient who uses deliverable fuel moves their household, and as a result the recipient has no direct relationship with a fuel supplier, a vendor must notify the landlord of the amount of remaining fuel in the tank of the WHEAP recipient tenant who has moved

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Revised: August 2025 from residence. Landlords must issue a refund to the WHEAP recipient tenant for the amount of fuel remaining. If unable to locate the WHEAP recipient tenant, the landlord shall issue a refund to the Division. The landlord is not permitted to retain the fuel or debit the refund against a balance owed. When a recipient moves out of state, the funds shall be refunded to the Division. The funds belong to the WHEAP recipient and/or the Division.

8.7.2 Crisis Benefits 1. If a recipient retains the same supplier with an active account, the credit balance remains with the supplier until exhausted. 2. If the account becomes inactive, a reasonable effort must be made to contact the applicant and/or the local WHEAP agency to identify the new fuel provider and transfer the credit to the new supplier. 3. If a new fuel provider cannot be identified, the funds should be refunded to the Division. 4. If the customer/applicant cannot be located, the funds should be refunded to the Division. 5. If a customer moves out of state, the credit balance must be refunded to the Division. 6. If a credit balance remains for a deceased applicant and the account is closed, the balance must be refunded to the Division. 7. When a WHEAP recipient who uses deliverable fuel moves their household, and as a result the recipient has no direct relationship with a fuel supplier, a vendor must notify the landlord of the amount of remaining fuel in the tank of the WHEAP recipient tenant who has moved from residence. Landlords must issue a refund to the WHEAP recipient tenant for the amount of fuel remaining. If unable to locate the WHEAP recipient tenant, the landlord shall issue a refund to the Division. The landlord is not permitted to retain the fuel or debit the refund against a balance owed. When a recipient moves out of state, the funds shall be refunded to the Division. The funds belong to the WHEAP recipient and/or the Division.

8.8 Lost, Destroyed, or Stolen Benefit Checks Single Party Check No action can be taken on checks or benefits that were issued in a prior program year. If an applicant contacts the local agency and states they have not received a benefit check that was issued in the current program year, or that it was stolen or destroyed, the applicant must complete a Stop Payment Request. Requests are processed by the Division, and result in one of two actions: • If the check has been cashed, the Division informs the local agency to inform the applicant. • If the check has not been cashed, the Division mails a replacement check to the applicant after the local agency confirms the mailing address and adds a System Note that they have confirmed the customer’s mailing address.

A Stop Payment Request includes completing a WHEAP Affidavit of Lost, Destroyed or Stolen Benefits Form, and should be completed in the following scenarios: 1. An applicant states they have not received a check. Please note the following: a. The check must have been issued within the current program year.

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121 Revised: August 2025 NOTE: Checks that are not expired because they were issued within the last 12 months, but were benefits issued on a prior program year cannot be reissued even if they are still outstanding. b. It must be at least 3-4 weeks since the check was issued. This is due to the process that is followed if the applicant moved to a new address, or the check was mailed to the incorrect address.

Checks cannot be forwarded to new addresses. Envelopes containing checks are stamped “Return Service Requested” and are returned to the local agency. Because this process takes an average of three weeks, agencies should be checking their returned mail in cases where the applicant has since moved or an incorrect mailing address was processed. 2. An applicant knows the check was received but the check has been lost, stolen, or destroyed regardless of when the check was issued.

Completing a Stop Payment Request 1. The agency completes the check information section of the WHEAP Affidavit of Lost, Destroyed or Stolen Benefits Form before presenting to the applicant 2. The applicant completes the remainder of the Affidavit and returns to the local agency 3. The agency reviews the Affidavit, then signs it 4. The agency provides a copy of the Affidavit to the applicant a. The agency shall upload the signed Affidavit to the “Other WHEAP Documents” repository of the associated application 5. The agency sends an email to the HE+ Help Desk stating an Affidavit has been uploaded to the HE+ System. The email shall include the following information: a. PID b. Applicant/case head name c. The application number associated with the upload 6. Add an HE+ System Note to the application that an Affidavit was completed by the applicant and a Stop Payment Request was sent to the Division

NOTE: The HE+ System only allows a worker from the agency that processed the parent application to upload documents. Consequently, agencies that process an Affidavit for a customer whose application was not processed by their agency shall email the Affidavit to the HE+ Help Desk and Division staff shall upload the Affidavit to the “Other WHEAP Documents” repository.

Results of the Stop Payment Request 1. The check has been cashed: a. The Division informs the local agency the check has been cashed so the local agency can inform the customer. b. If the applicant insists they did not cash the check, have the applicant complete form DOA-2789 (including the oath and notary signature) and form DOA-2790

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Revised: August 2025 (handwriting samples). The agency is required to upload form DOA-2789 and DOA- 2790 to “Other WHEAP Documents” and mail the originals of both forms to the Division within 30 days. The agency is required to add an HE+ System Note to document the forms were completed and mailed. i. Both forms can be requested by contacting the HE+ Help Desk. c. The WI DOA’s bank initiates a forgery investigation and issues a cashier's check if there is a settlement on the forged check. The bank that cashed the check may also initiate a forgery investigation. The process can take several months. The Division forwards the cashier’s check to the local agency’s WHEAP Coordinator for the applicant to pick up at the agency after presenting a valid photo ID. d. The applicant may wish to contact the local law enforcement authorities. 2. The check is outstanding: a. The Stop Payment is completed on the outstanding check. b. A WHEAP check, on which payment has been stopped, can be replaced only with a State Controller’s Office “S” series replacement check. “S” series checks are not generated through the HE+ System. c. The Stop Payment action and replacement check are recorded on the “Transaction Register” in the HE+ System. d. The Division mails the “S” series check to the applicant. If this is the applicant’s second request for a replacement check for the same benefit, the applicant is required to pick the check up at a local agency after presenting a photo ID. The agency is required to add an HE+ System Note to document the customer picked up the replacement check.

Single Party Check Issued to the Applicant in Error If the local agency becomes aware of information that would have made the case ineligible (whether or not the incorrect information resulted from fraud), and the check has not yet been cashed, or if the local agency becomes aware that the applicant is ineligible, the WHEAP agency must notify the Division in writing (an email to the HE+ Help Desk will suffice) and add an HE+ System Note. An Affidavit of Lost, Destroyed or Stolen Benefits Form, completed by the applicant, is not needed.

Vendor Checks Vendors do not have to complete an Affidavit of Lost, Destroyed or Stolen Benefits Form. The agency or vendor should contact the HE+ Help Desk when a check has not been received. Stop Payment and replacement checks can only be processed for checks issued in the current program year.

Stale-Dated Checks State-issued checks stale-date (expire) after 12 months from the date of issuance. These are recorded on the Transaction Register in the HE+ System as a “Cancelled Draft.” If an applicant requests that a stale-dated check be reissued (they just found the check or state they never received the check), agencies shall advise the applicant that this check cannot be replaced as it is stale-dated and was issued for a prior program year. Add an HE+ System Note to the application regarding the action taken.

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123 Revised: August 2025 Contact the HE+ Help Desk if there are any questions on prior program year’s lost, stolen, or destroyed benefits checks.

8.9 Overpayments and Applicant Repayments 1. The local agency must establish a separate file on overpayments that the recipient is required to repay any Regular WHEAP Benefits, Crisis Assistance benefits, HE+ Program Services benefits, and/or Weatherization services regardless of program year association, including those that are being recouped through the HE+ System. The file shall include: a. A list of those cases in which an overpayment may have been made b. The date the recipient was notified of the overpayment c. The disposition made, i.e., recovery d. The date and amount of any recovery or the amount of uncollectible funds 2. Regular heat and PB canceled during the heating season, and cancelled crisis benefits where “Vendor” is selected as responsible for paying back will be recouped by the HE+ System through subsequent regular and crisis heat or PB payments. 3. When “Client” is selected as responsible for paying back benefits, or when the customer still owes benefits when a single party payment is corrected, the WHEAP agency shall complete a Repayment Agreement and provide it to the customer for their signature. A Model WHEAP Repayment Agreement form can be found on HE+ TTA website under WHEAP │ Forms. A copy of the agreement shall be uploaded by the agency under “Other WHEAP Documents” until the signed original agreement is received. A copy of the signed agreement shall be provided to the customer, then uploaded to the HE+ System by the agency under “Other WHEAP Documents.” If the customer refuses to sign or return the original Repayment Agreement, the uploaded unsigned agreement shall serve as the record of repayment. Any benefits still owed by the customer when the next application is processed as the case head will have current year paid benefits reduced from the benefit awarded for the application. This will automatically be performed by the HE+ System even if an active repayment agreement is in place with the local agency. 4. When determining the overpayment amount for prior years, use the HE+ System benefit calculator with the correct information from the prior year(s) to determine the benefit amount the household should have received. Enter the difference in benefit, instead of including the full benefit, on the repayment agreement.

Overpayments should be payable to DOA/DEHCR and be mailed by the local WHEAP agency to the Division with a cover letter specifying the following: a. Name b. Full address c. Reason for the overpayment d. Indicate Heating, Non-Heating or Crisis Benefit, HE+ Program Services Benefit, Weatherization Services e. Name of WHEAP agency f. Date of the initial energy check or the appropriate heating season

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125 Revised: August 2025 Chapter 9 | Administration 9.1 Local Administration The Division contracts with counties, nonprofit organizations, and tribes for local administration and delivery of WHEAP.

County departments of social/human services, nonprofit organizations, or designated tribal offices are responsible for the local operation of WHEAP. Each agency must provide eligible households living within the agency’s jurisdiction with available WHEAP benefits and services.

Tribes contracted to provide WHEAP services are responsible for local program administration to applicants living within the borders of the reservation. Contracted tribes may send applicants living within the reservation borders to other WHEAP agencies contracted to serve tribal reservation lands within their general boundaries to provide services to households residing within the reservation boundaries.

9.2 Program Operations Each local agency must administer WHEAP within the guidelines, policies, and regulations set forth in the current year WHEAP Manual, the current year WHEAP contract with the WI DOA, DEHCR, relevant State of Wisconsin Statutes, and appropriate federal regulations.

9.2.1 General Local agencies shall: 1. Provide access to the HE+ TTA website to all WHEAP intake staff. 2. Require WHEAP online learning: a. Intake workers are required to complete WHEAP Basic and WHEAP 2.0 and must attain an 80% successful score prior to creating an HE+ System User profile and granting intake workers access to the HE+ System.

NOTE: Fiscal staff, directors, and clerical staff are not required to complete WHEAP Basic and WHEAP 2.0 training unless they are processing WHEAP application(s). 3. Agencies shall send at least one representative to any trainings or meetings identified by the Division as “required.” The Division may require agencies that serve multiple counties/territories to send additional representatives to select trainings and meetings.

If a WHEAP agency is unable to provide representation at the required meeting, training, or conference, a written explanation from the WHEAP Director shall be submitted a minimum of twenty-four hours before the start of the meeting, training, or conference.

Unexcused absences or agencies with a history of non-participation are subject to penalties as outlined in the WHEAP contract. 4. WHEAP agencies shall notify the Division on the same business day if they are unable to perform activities such as crisis activities and HE+ Program Services referrals.

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Revised: August 2025 5. Obtain prior approval from the Division for out-of-state conferences or training. See Section 9.3.2. 6. WHEAP agencies should not exceed meal reimbursement rates as established each Federal Fiscal Year by the U.S. General Services Administration (for the State of Wisconsin).

9.2.2 Public Information Local agencies are responsible for providing information to the public in the agency’s jurisdiction about WHEAP (energy assistance). This information must also be made available on the local agency’s website. The local WHEAP agency’s public information about the program must include at least: 1. The availability of energy assistance, Crisis Assistance, and Weatherization services 2. Eligibility requirements and how to apply 3. Identify the program as administered by the State of Wisconsin HE+ Program and include the HE+ logo on the local agency’s public website 4. Provide the link to the Division website WHEAP page.

In lieu of items 1-4 above, the local WHEAP agency may provide a direct link to the Division website. The link shall be titled, “Wisconsin Home Energy Plus Programs and Energy Assistance Application Information.”

HE+ and co-branding logos are required on all program materials prepared and published by the local agency. See Section 9.5.8.

The local WHEAP agency is required to: 1. Establish and publicize a local or toll-free telephone number where customers can call year-round for general WHEAP information. The publicized telephone number shall not allow customers to be on hold for more than two minutes before speaking with a staff person. Customers shall be provided with the option to immediately leave a voice message if they do not want to remain on hold. Messages must be answered in the order of receipt and no later than 48 hours from the date of the message. 2. Establish procedures to identify no-heat emergency telephone calls and to respond to the calls within the required timeframes (see Chapter 5 and the HE+ Program Services Manual). 3. Notify the Division and Weatherization agency of agency closures that affect normal business operations. This would include closures for training, inclement weather, etc. 4. Agencies do not need to notify the Division of holiday closures unless the closure may result in more than 2 consecutive workdays. For scheduled closures, notification should be provided at least 48 hours prior to the day of closure. 5. Notify the Division if any agency operations are unavailable. This includes, but is not limited to, phones, email, and scheduling system(s).

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127 Revised: August 2025 NOTE: WHEAP agencies shall not create or maintain an online application portal. Agencies shall only use the Division online application method.

9.2.3 Outreach 1. Agencies are required to provide outreach services to maximize participation of eligible persons for WHEAP benefits. Outreach activities must target households with disabled persons, elderly persons, children under six years old, and persons working at low wage jobs (working poor). The “outreach indicator” is a question on the paper and HE+ System application. See Section 4.4.4 for more information about the outreach indicator. 2. Agencies are required to prominently display the HE+ Weatherization/WHEAP Co-Branding Poster in the agency’s main waiting area for WHEAP intake. WHEAP agencies are encouraged to also display the poster in intake workers’ offices, outreach locations, and other appropriate areas. Agencies may choose to develop and display their own WHEAP posters provided they contain the HE+ logo and the county/tribe specific co-branding logo. See Section 9.5.8. 3. Agencies are encouraged to play the HE+ Weatherization/WHEAP video(s)* in agencies’ main customer service waiting areas. Agencies shall make the HE+ video(s) accessible via electronic media such as Facebook, Twitter, and/or the agency website, if feasible.* 4. Agencies shall reference the link to the Division website WHEAP page, via electronic media such as Facebook and Twitter if feasible. 5. Agencies are required to ensure that persons with limited English proficiency (LEP) have meaningful and equal access to benefits and services. The agency is required to provide spoken interpretation in addition to translated written publications as some individuals may not read English or other languages. The agency must have a mechanism to communicate orally with people with LEP. Providing the Spanish version of the HE+ Application is not fulfilling this policy requirement. If the applicant requires spoken communication and/or explanation in addition to the translated application, agencies shall ensure verbal interpretation is available. 6. Agencies are required to provide services to the disabled and impaired, including but not limited to assisting applicants with the completion of the application form, translation of material, interpretation services for deaf persons, and reading services for blind persons. 7. Agencies must establish HE+ Application methods that are accessible to targeted households and process submitted online applications within a reasonable time. 8. Agencies must comply with federal law and provide an alternate intake method separate from a site which administers W-2/TANF. All agencies are compliant due to the implementation of online applications. 9. Agencies must assist with the preparation and submittal of applications by persons who are homebound. 10. Agencies must arrange an early application period for persons in targeted groups and high-risk households. 11. Agencies are required to have a Program Operations and Community Service (POCS) Plan. The Division-provided template is available on the HE+ TTA website under WHEAP │ Forms. Each agency is required to review their current plan and update the date reviewed

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Revised: August 2025 section on the plan before the start of each program year. The goal of this plan is to provide agencies with a means to describe how the agency will conduct outreach, identify and enroll eligible households in their communities, and reach targeted households. The POCS Plan should indicate what other community resources/stakeholders play a role in this outreach effort and identify key stakeholders that the agency coordinates efforts/referrals with. In addition, the list should indicate the local agency's contact person and the resource services provided. The plan must be made available to the Division upon request. 12. Agencies may establish interagency agreements with other low-income program offices to perform some of the outreach activities to targeted groups.

*The HE+ videos are on the HE+ TTA website under Administration | HE+ Videos.

9.2.4 Agency Information Each WHEAP agency shall review the following information for accuracy before the start of each Federal Fiscal Year (October 1). 1. In the HE+ System, the name, address, phone numbers, and email addresses of person(s) responsible for administration and operation of WHEAP. Additionally, verify agency staff are listed with the correct positions, including: a. A Director (party responsible for signing the contract and oversight of the program) b. At least one WHEAP Coordinator (party responsible, at a minimum, for the high- level administration) c. Fiscal staff d. No more than two* PMAs 2. In the HE+ System, the business address(es) and telephone number(s) for applicants to contact and to be displayed on computer-generated notification letters. a. In the HE+ System, this information is found via the business view page under “Locations” in the “General” section. Click on the address for the business location to view business location details: the physical address, mailing address, and phone number. 3. Contact information on the Division website. 4. Ensure the agency is meeting the alternate intake and outreach requirements of the federal law.

*If an exception is needed to this limit, please contact the HE+ Help Desk. This request must be submitted on an annual basis.

9.2.4.1 Updating Agency Information The agency is responsible for ensuring that all contact information in the HE+ System is up to date. Any changes to WHEAP contacts, including key positions (Director, Coordinator, Fiscal, etc.), must be updated in the HE+ System by the agency. The agency shall also notify the Division, via the HE+ Help Desk, when there are any changes to the Coordinator, Director, and/or Fiscal staff.

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129 Revised: August 2025 Changes to business locations, mailing addresses, agency phone numbers, or the PMA must be changed by the Division. Submit any updates in writing to the HE+ Help Desk.

9.2.5 Intake The local WHEAP agency must conduct intake for the WHEAP and Weatherization programs. The intake program, at a minimum, is required to: 1. Establish a location for the distribution and receipt of applications 2. Provide flexible office hours to accommodate applicants who cannot apply during normal business hours 3. Ensure all application sites are accessible to persons with physical disabilities 4. Ensure application sites are physically and geographically available for all potential applicants within the county/tribal jurisdiction 5. Provide for an alternate intake method (as required by federal law), such that an applicant is not required to apply in person at a site where W-2/TANF is administered 6. Develop a working relationship with the local Weatherization operator(s) a. The Division provides the Weatherization agencies with a list of potential applicants based on applicants who have received regular WHEAP benefits b. Agencies may provide the applicants with the name, phone number, and address of the local Weatherization operator

In accordance with Department of Energy (DOE) Weatherization Program Notice 10-08, agencies are required to keep confidential any specific identifying information related to an individual’s eligibility for the HE+ Program, or the individual’s participation in the HE+ Program.

Each WHEAP agency, in its entirety, must comply with the Agency Guidelines for Handling Sensitive Data (Appendix A).

9.2.6 Complete and Process Applications Local WHEAP agencies are required to take applications and assist applicants in completing the HE+ Application. Applications must be taken throughout the year to establish eligibility for Prevention Assistance and Weatherization Assistance after the heating season is over, and for regular energy assistance benefits and Emergency Crisis Assistance during the heating season.

Chapters 3, 4, and 5 of this manual, and the HE+ Program Services Manual describe how to process applications for Regular WHEAP Benefits, Crisis Assistance, and HE+ Program Services. In addition, each agency is responsible for: 1. Entering HE+ Applications into the HE+ System within 30 days of the application date. NOTE: Regardless of the actual date when an early application is taken by the local WHEAP agency, the HE+ System processes the early application like an October 1 application. a. If an extraction is delayed, all processing of payments and notifications are also delayed.

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Revised: August 2025 2. Verifying application information and viewing supporting documents to certify the application data is accurate. 3. Entering multifamily building applications into the HE+ System within 30 days, or less, for the local Weatherization operator to achieve the number of eligible dwelling units needed to make the building eligible for Weatherization Assistance. 4. Entering all applications into the HE+ System in chronological (date) order. Applications will be processed using the data from the first chronologically entered application. See Section 4.3.4. 5. Ensuring applications are complete, unless applicant withdraws or fails to provide required information. 6. Resolving application and check issuance problems. 7. Documenting the receipt and resolution of all complaints. a. Documentation shall be made available to the Division upon request.

NOTE: See Section 4.3.4 for additional information on processing online applications.

9.2.7 Crisis Assistance Each WHEAP agency is required to provide Emergency Crisis and Prevention Assistance services to assist applicants with home energy costs. It is important for WHEAP-contracted tribes to provide these services to households within their reservation. County agencies with WHEAP-contracted tribal reservation lands within their general boundaries may provide services to households residing within the reservation boundaries.

9.2.7.1 Contract Spending WHEAP agencies shall budget the full WHEAP contract allocation for twelve months of activity. Time reporting is strongly encouraged for budgeting and for reporting of actual expenditures. Each account line must be expended according to its intended use and no account line shall be spent egregiously.

Monthly expenses to Crisis Services shall be spent within a reasonable ratio in comparison to the number of crisis applications the agency has processed by month. The Division will determine a reasonable ratio based on program operation factors and comparisons. Each crisis benefit issued requires crisis activity by the agency intake staff, which should be expensed to the Crisis Services contract account line. Some crisis activities will not result in a crisis benefit to an applicant, yet still may be an expense to the Crisis Services contract account line.

Monthly expenses to “Operations” (LIHEAP/PB-WHEAP/PB-Wx) shall be spent within a reasonable ratio in comparison to the amount of regular applications processed by month.

9.2.8 HE+ Program Services See the HE+ Program Services Manual, located on the HE+ TTA website under HE+ Program Services | Manuals & Guides and on the Division website under Provider Resources | Energy | HVAC/Water Conservation Assistance | Manual and Forms, for details of the WHEAP agency’s responsibilities.

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131 Revised: August 2025 9.2.9 Fraud All agencies are required to have procedures in place to handle fraud. If the local agency suspects fraud, it shall collect all information available about the case. Agencies shall contact the Division with all collected information. The Division will conduct a high-level investigation and provide the agency with all findings. Agencies shall take appropriate action and respond to the Division within five (5) business days with the results of the investigation.

If a fraud referral is sent to the agency from the Division, the agency shall respond to the Division within five (5) business days with the results of the agency’s investigation and with the agency’s course of action.

In the case of any claim or statement made by any individual (case head or other household member(s)) relating to any of the benefits received, the individual(s) may be held liable for penalties and assessments under the Code of Federal Regulation Title 45, Subtitle A, Section 79.3.

Upon completion of the investigation, determine if any benefits (LIHEAP, PB, Crisis, Program Services, and/or Weatherization) were awarded to applicants who were not eligible, or if a benefit overpayment occurred. If it is determined that fraud occurred, proceed with a cancel/refund with the current program year application. If fraud is committed on prior program year application(s), the agency shall complete a HE+ Repayment Agreement with the customer of any benefits affected by the inaccurate information. Refer to Section 8.9 if there is a need for an HE+ Repayment Agreement.

HE+ System Notes are required for all fraud investigation cases. Contact the HE+ Help Desk for assistance.

Refer to Section 7.3.6.3 regarding errors which affect weatherization.

Refer to Section 8.9 to ensure compliance with maintaining a file of overpayments.

In order to mitigate fraud and maintain program integrity, agencies shall ensure compliance with all applicable elements of Appendix A. If requested by the Division, agencies shall identify all steps taken to comply with Appendix A.

Report all incidences of worker fraud to the Division. The Division will provide guidance to the local agency regarding inactivating the contact and user profile of a worker who is under investigation for fraud.

9.3 Contract and Fiscal It is every WHEAP agency’s responsibility to read and understand the WHEAP contractual obligations. In addition, the agency acknowledges the fiscal responsibilities outlined in the WHEAP contract and the WHEAP Manual. Direct all questions and comments to the HE+ Help Desk.

9.3.1 Payment for Contract Services Funds for LIHEAP Operations, LIHEAP Crisis Services, PB - WHEAP Operations-Outreach, and

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Revised: August 2025 WX Operations-Outreach are allocated to WHEAP agencies through a direct contract with the WI DOA. Not all counties/tribes receive funding in LIHEAP Operations and LIHEAP Crisis Services.

If an agency elects to relinquish WHEAP-related activities back to the Division, it shall notify the Division within 30 days before the relinquish date. The Division requests agencies provide notification at least 60 days before relinquishing WHEAP-related activities, if possible, to ensure a smooth transition for clients to a new provider.

Expenditures for these allocated funds are invoiced for reimbursement by agencies on the HE+ System. Only staff with appropriate security clearance can access the contract/invoice module of the HE+ System.

WHEAP agencies are required to complete an Authorization for Direct Deposit to receive payments via Automated Clearing House (ACH).

The Division does not provide a specific tracking tool for the agency to manage the reporting of expenses. The Division recommends that 100% time study be used for the most accurate method to track WHEAP activities.

HE+ Program Services expenses for services, like Regular WHEAP Benefits, are paid by the Division and not from funds allocated to the WHEAP agency.

For accounting purposes, the Catalog of Federal Domestic Assistance (CFDA) number of the LIHEAP program is 93.568.

The State Grant Identification number for the utility PB program is 505.371.

9.3.2 Out of State Travel Agencies wishing to use WHEAP funds (LIHEAP or PB) to have more than two staff attend out-of- state conferences or training must obtain prior approval from the Division. Agencies must submit a request, at least one month in advance, identifying the staff they wish to send and a justification for their attendance. The justification must include estimated total costs, reference to the specific workshops/programs they plan to attend and an explanation of how this knowledge will contribute to the agency’s performance or quality of work. Any travel out of the country for WHEAP purposes must be reported to the Division in advance of the travel.

9.3.3 Computer Equipment, Connections, Security, and Costs The agency shall be responsible for the following: 1. All costs for hardware, software, and internet access required for WHEAP delivery. An agency shall have all computer hardware (equipment that allows a user to create, store, or transmit data), software (computer application/program or data), and service subscriptions, including but not limited to email hosting and desktop support, necessary to meet general requirements for program management and financial reporting. Computers, laptops, tablets, and desktop personal computers (PCs) shall use a version of Microsoft (MS) Windows® operating system. Productivity software loaded on computers shall be a version of MS Office® compatible with Division software. Transmittal of MS Office® files shall be in

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133 Revised: August 2025 MS Word, MS Excel, MS PowerPoint, MS Access (Wx Assistant), or Portable Document Format (PDF) file format. Other file formats may be transmitted upon request of the Division. All data handling shall be in compliance with Appendix A. a. An agency shall have reliable access to the Internet at a sufficient connection speed to meet business requirements. An agency shall make their own hardware and software purchases. An agency shall track and maintain all computer hardware, software, and services that are purchased with WHEAP funds. An agency shall procure all computer hardware, software, and services in accordance with all applicable federal and state guidelines and laws. b. An agency shall make full specifications and disclosure of computer hardware, software, and services available to the Division upon request or during monitoring. 2. Communication and cooperation with the Division for the installation and maintenance of all computer equipment specifically related to WHEAP. 3. Appointing no more than two* HE+ System PMAs with a written request to the Division via the HE+ Help Desk, who is responsible for: a. Notification to the Division System Administrator(s) in writing (email is acceptable) of any changes to these appointments** b. Creation of new, and maintenance of current, HE+ System contacts/permissions/user profile/position information (including review of the user profile name for appropriateness upon creation) within their county/tribe, including signed security agreements for each HE+ System user c. Maintenance of current HE+ System user profiles including: i. Inactivating user profiles that will be off the HE+ System for more than two weeks on vacation, maternity leave, summer leave, or any other reason 4. Access for filing administrative invoices is limited to county/tribe staff only. 5. Assigning the “Supervisor” security permission to at least one WHEAP staff person of a supervisory role within the agency (or designated by a person with a supervisory role). See Section 4.1.10 for more information.

*If an exception is needed to this limit, please contact the HE+ Help Desk. This request must be submitted on an annual basis. **The creation of or changes to a PMA in the HE+ System must be completed by DEHCR.

9.3.4 Allowable Costs This section provides a description of allowable costs, by contract line. The agency shall expend funds provided under the contract in accordance with these policies.

9.3.4.1 LIHEAP Operations Accounts 1. Allowable program operations costs include: a. Staff costs to accept and process HE+ Applications throughout the contract period b. Verifying application information c. Processing applications, including entering data into the HE+ System

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135 Revised: August 2025 5. Distributing posters, flyers, or other informational material regarding HE+ Programs to potentially eligible persons 6. Providing information on eligibility criteria, application sites, etc. to local media 7. Producing and mailing information to potentially eligible persons, ensuring that the WI DOA, HE+ Program is referenced on any published material 8. Coordinating with other local program offices serving persons in targeted low-income groups, including arranging for WHEAP information and/or application intake to be provided in conjunction with other programs 9. Preparing and disseminating early applications and the costs associated with that preparation and dissemination, including intake, and entry into the HE+ System, of early applications

9.3.5 Disallowed Costs Disallowed costs are expenses, as determined by the Division, which are not reimbursable using WHEAP contract funds. If the Division cannot determine if an expense is allowable because of inadequate records or documentation, the cost may be disallowed. Agencies shall reimburse the Division for any disallowed cost.

9.3.6 Performance Measurement The Division expects each WHEAP agency to administer WHEAP in a timely and professional manner. The following performance measures will be annually expected of the agency: 1. Agency shall maintain or increase the current WHEAP paid caseload compared to prior year’s caseload* 2. Agency shall meet the contract spending requirements as outlined in Section 9.2.7.1 3. Agency shall conduct general and HE+ Program Services quality assurance reviews as outlined in Chapter 6 4. Agency shall coordinate outreach/intake activities with other local organizations 5. Agency shall develop and coordinate outreach efforts and referral activities with their Weatherization agency

*Documentation of conducted outreach activities, marketing efforts, agency plans, and local intake methods shall be made available upon request.

9.4 Financial Standards Each WHEAP agency is held to certain financial standards and is required to maintain financial records in accordance with the guidance in this section. WHEAP agencies are subgrantees of Federal Block Grant funds and grantees of State of Wisconsin PB funds and are accountable for expenditures of the funds allocated to them.

9.4.1 General Agencies shall establish and maintain fiscal control and accounting procedures as set forth in Wisconsin Statutes §46.036(4). These procedures shall be in writing and consistently applied.

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Revised: August 2025 Agencies shall maintain account books on a double entry basis. Accounting will be on a modified accrual basis at a minimum. Full accrual basis accounting is encouraged. Agencies shall maintain separate accounting for each contract. The agency shall maintain records that separately track and account for expenses to each account line of the contract. There shall be a system for allocating common expenses among operational account lines.

If work is performed by the agency’s staff, charges to WHEAP will be made on an actual cost basis. Agencies are required to notify the Division of any potential financial conditions that could adversely impact program operations. Examples of these conditions include pending legal activity, organizational cash flow shortages, and/or allegations or investigations of fraud or embezzlement. Failure to notify the Division of potentially adverse financial conditions is grounds for immediate termination of the contract.

9.4.2 Source Documentation Agencies shall maintain at least the following documentation of contract funds: 1. Approval to secure funds 2. Applications and requests for modifications 3. Signed contract and modification approvals 4. Board minutes 5. Proof of receipt/deposit slip, when applicable, including date, amount, source of funds, and identification of receipt of funds in cash ledger

9.4.3 Expenditure Documentation Agencies shall maintain, at a minimum, the following documentation of expenditures: 1. Invoice/purchase order/receipt 2. Travel authorization 3. Employee contract or time records approved by employee and supervisor

9.4.4 Financial Record Retention Agencies shall retain all financial records for five years.

All records maintained in accordance with the operation of WHEAP shall be available to the Division on request for inspection, examination, excerpting, transcription, or audit. The minimum acceptable records include, but are not limited to: 1. Documentation of employee time 2. Documentation of all materials, supplies, and travel expenses 3. Inventory records and supporting documents for allowable equipment purchased to carry out the scope of work of the program 4. Documentation and justification of the methodology used for any in-kind contributions 5. Justification supporting allocation of space charges or other indirect cost allocation methods

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137 Revised: August 2025 6. Any other records that support charges incurred

Agencies shall maintain sufficient segregation of accounting records for this program separate from other contracts, projects, and programs.

9.4.5 Open Records/Public Records An agency is subject to State Public Record laws, (Wisconsin Statutes §19.21-19.39). These laws relate to record retention by the agency and to the provision of information (known as “complete public access”). Division policy is to: 1. Forward a written copy of all records requests to DOA, DEHCR or directly to DOA, Office of the Secretary, Legal Office, PO Box 7864, Madison, WI 53707-7864, and 2. Provide records to requestors, as required, or 3. Request that DOA coordinate the response to the records request.

9.4.6 Financial Audits Agencies shall ensure that financial audits are: 1. Conducted annually 2. Conducted by an independent auditor 3. Timely 4. Submitted to the Division as soon as available. Audit reports, including any accompanying letter of findings should be emailed as a text searchable, unsecured PDF file to: DOABFMSingleAuditCoordinator@wisconsin.gov 5. Conducted in accordance with federal laws and regulations, OMB Circular A-133 and the State Single Audit Guidelines (SSAG) issued by the WI DOA. Current SSAG for DOA is available online.

9.5 Administrative Requirements Each WHEAP agency is required to operate WHEAP under the administrative standards in this section.

9.5.1 Conflict of Interest Policy Each WHEAP agency shall develop*, implement, and keep on file a plan/written policy for managing potential conflicts of interest. Conflicts of interest covered by the plan/written policy shall include all situations, actual or perceived, when the agency, agency staff, members and relatives of the agency’s board of directors, and friends and relatives of agency staff may receive personal benefits or employment from WHEAP. At a minimum, the policy shall set forth the procedures and steps the agency will follow to address the following situations: • Agency staff processing WHEAP applications for which they have a familial, financial, or other connection to the case head, household members, landlord, or other party that would benefit either directly or indirectly from approval of the application • Hiring and supervising agency staff to avoid nepotism.

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Revised: August 2025 *WHEAP agencies may use existing conflict of interest plans to implement WHEAP. The policy shall be made available to the Division upon request.

9.5.1.1 Conflict of Interest Policy/Non-Disclosure Agreement All agency staff who work with WHEAP are required to agree to the Conflict of Interest Policy/Non- Disclosure Agreement. All staff with HE+ System access will be prompted to agree to the Conflict of Interest/Non-Disclosure Agreement Form upon gaining access to the HE+ System. This agreement is for the duration of employment with the agency. For staff who work with WHEAP but do not have HE+ System access, agencies shall require staff members to sign a Conflict of Interest policy. A copy of the Conflict of Interest/Non-Disclosure Agreement Form may be requested from the Division. This agreement is for the duration of employment with the agency and shall be retained by the agency for the duration of the employee’s employment.

Prior to performing intake or completing WHEAP-related activities, every worker must agree to the Conflict of Interest Policy/Non-Disclosure Agreement that contains the following:

Conflict of Interest Policy/Non-Disclosure Agreement No person who is a WHEAP agency employee, or agent or consultant, and who performs or has performed any functions or responsibilities with respect to WHEAP contract activities, may obtain a personal or financial interest or gain an unfair advantage of the program. This does not preclude any individual from applying for the HE+ programs. Furthermore, the same person may not have an interest in any WHEAP-related contract, or WHEAP-related proceeds, either for themselves or those with whom they have family or business ties, during their tenure. Receipt of earnings from the local WHEAP agency by employees shall not be considered a conflict of interest, but otherwise employees of the local WHEAP agency shall be fully bound by the requirements of this Policy. Upon request, the Department may make exceptions to this requirement after full disclosure and where the Department determines, in consultation with federal agencies if necessary, that such an exception is in the best interest of the State and is not contrary to state or federal laws.

9.5.1.2 Processing Applications of Relatives and Friends If the applicant is an employee of the agency, a relative or household member of an employee, a former employee of the agency, or a close friend of the person certifying/entering the application, applications must be reviewed and approved by a staff person at a supervisory level or higher. A staff member holding the HE+ System “Supervisor” permission must enter the application in the HE+ System and enter an HE+ System Note indicating the manager/supervisor who reviewed the application. This restriction applies to any actions related to the individual’s Regular WHEAP Benefits, Crisis Assistance, and HE+ Program Services applications.

9.5.2 Lobbying Restrictions WHEAP funds may not be used to influence federal contracting nor financial transactions. This restriction includes, but is not limited to, the following activities: • Agencies may not use federal funds (including LIHEAP) to pay a person(s) to lobby on their behalf with the Executive or Legislative Branch in connection with the award of a specific contract, grant, or loan.

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139 Revised: August 2025 • Agencies receiving more than $100,000 in federal funds per year must file with the U.S. Department of Health and Human Services an annual statement certifying that they will abide by these restrictions. • Agencies must disclose any payments made to a person(s) lobbying, as defined above, even if no federal funds are used to make the payment.

The form for agencies to disclose lobbying activities is available online.

9.5.3 General Record Retention Agencies shall retain all paper WHEAP records for five years unless already retained as an upload to the HE+ System.

The agency must maintain the following records as required in other sections of this manual including: 1. A record management system that retains documents for a period of five years from the date an application is submitted. Agencies may retain records locally in an electronic format to reduce storage space needs (see Appendix A). The Division maintains the record retention of any documents that are uploaded to the HE+ System dependent upon the worker verifying the document upload is viewable/accessible at the time of the document upload. If forms are required to be retained longer than five years, as outlined in the manual, the agency must retain those particular forms in accordance with the WHEAP Manual. 2. Files on all applicants including the entire completed (if applicable), signed, and certified application form(s) DOA-9549. a. If the application is completed interactively, only the applicant signature form must be retained as a document upload. 3. Any documents used to verify income (paystubs, wage printouts, S-GIRF, tax forms and/or schedules, etc.). SSNs on the tax records shall be redacted by crossing out all but the last four digits of the SSNs on all forms and schedules provided. Bank routing information and tax preparer ID shall also be redacted. 4. When applicable, retain Authorized Representation and/or Power of Attorney (POA) documentation as a document upload. 5. All records associated with the requirements set forth in the HE+ Program Services Manual. 6. The agency may retain additional records beyond the minimum established and shall be handled within the specified requirements of Appendix A. 7. Conflict of Interest/Non-Disclosure Agreement Forms for WHEAP staff without HE+ System access (see Section 9.5.1.1). 8. All signed and completed WHEAP Affidavits of Lost, Destroyed or Stolen Benefits forms as a document upload to the associated application “Other WHEAP Documents” repository in the HE+ System.

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Revised: August 2025 Electronic files of the following are maintained on the HE+ System: 1. Registered fuel suppliers 2. Weekly check registers for payments through the heating, PB, crisis, and HE+ Program Services programs

9.5.4 Staffing The agency must maintain staffing adequate to provide: 1. Program information year-round on both WHEAP and Crisis Assistance 2. Ability to take applications throughout the calendar year to assist applicants with home energy needs and to assist Weatherization agencies in determining eligibility of potential Weatherization recipients 3. Outreach activities throughout the calendar year 4. Emergency Crisis services during the heating season 5. Crisis Prevention services year-round 6. HE+ Program Services year-round

9.5.5 HE+ System Security 1. The WHEAP agency must appoint a PMA with a written request to the Division via the HE+ Help Desk. Any changes to this appointment require written notification to the Division. The creation of or changes to a PMA in the HE+ System must be completed by the Division. The PMA is responsible for: a. Creation of new and maintenance of current HE+ System contacts, permissions, user profiles, and position information (including review of the user profile name for appropriateness upon creation) within their agency b. Maintenance of current HE+ user profiles including: i. Inactivating user profiles who will be off the system for more than two weeks on vacation, maternity leave, summer leave, or any other reason ii. Immediately inactivating contacts and user profiles who have been terminated, retired, quit, or otherwise have left the program 2. Any staff with a user profile has the responsibility to maintain their user login name and password as confidential. Persons’ “Login Name” and password shall never be shared, even with other WHEAP staff. The user logged in is responsible for all activity occurring under this user profile. All activity in the HE+ System is recorded and time stamped according to the user login.

9.5.6 Coordination Agencies must coordinate efforts with other local agencies serving low-income households and/or providing energy assistance. This includes working with the vendors who are not participating in PB. Agencies are required to have a completed POCS Plan using the Division-provided template (located on the HE+ TTA website under WHEAP │ Forms). Each agency is required to review their current plan and update the date reviewed section on the plan before the start of each program year. The POCS Plan should indicate what other community resources/stakeholders play a role in

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141 Revised: August 2025 this outreach effort and identify key stakeholders that the agency coordinates efforts/referrals with. In addition, the list should indicate the local agency's contact person and the resource services provided. The goal of this plan is to provide agencies with a means of establishing their planned approach for conducting WHEAP outreach and achieving an effective and inclusive community outreach partnering with local organizations on ideas and culture to reach the entire community. Agencies are required to make the plan available to the Division upon request.

9.5.7 Publications The Division prints a variety of informational materials that are useful for outreach activities. Each July, orders are solicited from agencies for a program year’s supply. Limited quantities are available at the Division for small orders of additional print materials. Requests can be sent to the HE+ Help Desk.

NOTE: Most forms and documents are available for print via the Division website.

9.5.8 Home Energy Plus and Co-Branding Logos Agencies may develop, print, and publish their own WHEAP informational materials such as brochures, program marketing and outreach materials, and websites. Program materials prepared by the local agency that will be available to the public shall: 1. Include information on all HE+ programs 2. Identify the program as being administered by the State of Wisconsin HE+ Program 3. Include the two official logos: the HE+ logo and the county/tribe-specific co-branding logo

The following guidelines apply whenever using HE+ logos: • Changes or additions to the logo are not allowed • Program materials prepared by the local agency that will be available to the public shall include the logo and identify the program as being administered by the State of Wisconsin HE+ Program o Documents used only for internal purposes do not require a logo • Outreach materials will be reviewed as a part of the monitoring process and shall be made available at any other time to the Division upon request • Agencies are not required to seek pre-approval of marketing materials unless otherwise instructed • Agencies shall not use their own logos in lieu of the HE+ logo

The official HE+ logo and further usage guidelines can be obtained on the HE+ TTA website under Administration │ HE+ Logos. The co-branding logo is specific to each county/tribe and is distributed directly to each agency from the Division. It is each WHEAP agency’s responsibility to advise the Division of any changes with organizations identified in their logo. Contact the HE+ Help Desk if a copy of the co-branding logo is needed.

9.6 Monitoring The agency is responsible for participating in Division-conducted Administrative Reviews.

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Revised: August 2025 Participation includes, but is not limited to: 1. All requested individuals must be present at the specified times during Administrative Reviews 2. Providing the Division designee(s) with internet access 3. Providing the Division designee(s) with access to program-related electronic files and program-related paper files 4. Providing the Division designee(s) access to other program-related information as requested 5. Responding to Division requests and recommendations within the established timeframes

The Division conducts WHEAP DTMs of heating and non-heating assistance, Crisis Assistance, HE+ Program Services, outreach, and alternate intake. The agency is responsible for any Division- requested follow-up resulting from DTM.

The local agency is responsible for regular monitoring of heating and non-heating assistance, Crisis Assistance, HE+ Program Services, outreach, and alternate intake.

9.7 Disaster Planning In the event that a disaster prohibits all or some of the normal functions of program administration, the agency disaster plan directs the continuance of essential services. Agencies are required to make the plan available to the Division upon request.

9.7.1 Local Agency Continuity of Operations Plans Agencies are required to maintain the most up-to-date plan on file and make the plan available to the Division upon request. WHEAP agencies are all required to develop and maintain the continuity of operations plans. Each entity is responsible for sharing the completed plan with applicable stakeholders and fuel providers to inform them of the procedures in case of a disaster or emergency.

Local agencies must provide the Division the names of their primary emergency contact and two back-up contacts. The document(s) must include such contact information as may be necessary to ensure a contact is available 24 hours per day, every day including weekends and holidays.

9.7.2 Division Plan In the event a disaster occurs that affects the ability of the Division to provide services in the normal way, a plan has been developed to identify ways to maintain essential services. The primary actions are outlined as a means of notifying local agencies about what to expect. 1. State Level Actions The Division will send letters to all State-approved WHEAP vendors explaining the Division contingency plan. The letter will specifically notify them that contractors are authorized by the State to pre-authorize payment for deliveries in case of failure of the state benefit payment system or the telecommunications links with the state computer system or the Division.

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143 Revised: August 2025 2. Contractor Requirements a. Contractors are required to report any changes in writing (email is acceptable) to the: i. Name of the WHEAP county/tribal Director ii. Name of the WHEAP Coordinator iii. Physical address iv. Mailing address v. Phone numbers (including extension(s) if applicable) vi. Fax numbers vii. Email addresses reported to the State for statewide broadcast messages b. Contractors are required to have voicemail and/or an answering machine message available year-round with the following information available to the caller: i. The emergency number to call for heating emergencies from October 1 through May 15 ii. Office hours for applying for energy assistance/Crisis Assistance and where to apply from October 1 through May 15 iii. From May 16 through September 30, a message that the heating season/Emergency Crisis Assistance is over but there may be Prevention Assistance available and how to apply iv. When it is time for early applications, a message describing when early applications begin and how to apply c. Contractors are required to have the following plans in place in the event of a disaster: i. Contractors shall contact their State-approved WHEAP vendors by letter outlining their procedures in case of business failure to ensure pre- authorized payment for deliveries ii. Contractors shall be expected to have in place a back-up system for communicating with or reaching fuel suppliers in an emergency if the phone system is inoperative iii. Contractors shall have in place after-hours emergency service procedures. The personnel responsible for after-hours service shall be trained on disaster emergency procedures, including the pre-authorization procedures for guaranteeing emergency payments in cases of a disaster iv. Contractors shall have procedures to handle emergencies during normal hours of operations if the operations of the local office are interrupted v. Contractors shall coordinate with the local office of emergency government, local law enforcement agencies, and other local service providers to ensure they are aware of WHEAP's procedures to assist in emergency situations involving heating fuel or utility service vi. Contractors shall have paper applications in their offices to take applications, to determine eligibility, and to guarantee pre-authorized payments for deliveries

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145 Revised: August 2025 Chapter 10 | Contract Invoicing 10.1 General Allowable costs are described by line in Section 9.3.4.1 through Section 9.3.4.3.

10.2 Invoice Filing Responsibility It is the responsibility of the WHEAP agency to invoice and/or approve expenses per the State and agency contract that is from October 1 through September 30 of each year. The last day for a local agency to submit an invoice for the contract that ends on September 30 is at the close of business on November 15 of each year, when a final closeout contract extraction will occur. Invoices submitted after this date for a previous contract year will not be processed for payment.

Agencies must submit a final “Close Out” invoice regardless of their contract balance or existence of expenses. The “Close Out” invoice must be submitted and in “Approved by Primary” status prior to close of business on November 15 of each year. The “Close Out” invoice is only available when invoiced expenses have been paid through September. To create a closeout invoice, select “Add a Close Out Invoice” from the Action Ribbon on the HE+ System and follow the same steps for “Creating an Invoice.”

10.3 Guidelines for Invoicing The WHEAP agency is required to invoice for reimbursement of expenses in the HE+ System. WHEAP expenditures shall be invoiced monthly.* Expenses may not be invoiced until the first of the following month (example: October expenses may not be entered into the HE+ System until November 1). • Expenses submitted by each WHEAP agency shall be actual expenses. • Monthly expenses shall not be invoiced for 1/12th of the contract. • Expenses for the previous month must be entered (invoiced) in the HE+ System by the 30th of the current month. • The HE+ System will not allow creation of more than one invoice per extraction. • If a correction needs to be made to a previously paid monthly invoice, the correction (positive or negative) shall be added/subtracted from the expenses entered on a subsequent invoice. For example, if the total WHEAP expenses for March are $5,000, but a correction of an additional $500 needs to be made to the December invoice, the total expenses entered for March would be $5,500. A note shall be added to the current invoice identifying the correction and the amount. An invoice can be edited until the point of extraction. • “Zero” shall be entered as an amount if there are no expenses to be invoiced for a specific account line for the current invoice. A note shall be entered to explain any “zero” entries to provide an explanation to the Division. Notes are not required if the account funding has been fully expended.

*Any WHEAP agency with an initial contract allocation of less than $30,000 shall invoice for reimbursement as needed but must remain in compliance with Article 25 Financial Management of the WHEAP contract. The Division encourages monthly invoicing.

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Revised: August 2025 • Once all amounts have been entered, the invoice is ready to be approved. Approval is only available to authorized agency staff. • The individual approving the invoice in the HE+ System shall not be the same individual who created the invoice in the HE+ System.** • Agency staff shall notify their county/tribal Treasurer, to whom the payment is issued, when an invoice has been marked as “Approved by Primary.” This ensures that payments are promptly processed.

**If an exception is needed to the two-tier approval, please contact the HE+ Help Desk.

Only invoices with “Approved by Primary” status will be processed for payment. It is the responsibility of the local agency to ensure that all invoices are in “Approved by Primary” status before the final contract closeout extraction. Invoices remaining in “Draft” status following the contract closeout period will not be paid.

10.4 Reimbursement Payments Agencies are required to receive contract payments electronically. To sign up for electronic payments, agencies must submit a completed form DOA-6456, Authorization for Direct Deposit. Agencies shall also provide either a “VOID” check or a letter from their banking institution on the bank’s letterhead confirming the account and routing numbers. Do not provide a starter check. The completed form and accompanying document(s) may be emailed to: DOADLDEHCRFiscal@wisconsin.gov

The Department conducts invoice reimbursement payments daily.

The Division shall not provide reimbursement if the maximum amount of the contract has been paid to the agency. Agencies shall not submit expenses to any contract account line once allocated funds have been expended. Once a contract account line(s) has been expended, agencies should continue to submit monthly invoices with $0 entered for the expended account line(s).

Payments which exceed allowable costs incurred and paid by the agency pursuant to the terms of the WHEAP contract, if outstanding at the expiration of the WHEAP contract, shall be repaid to the Division within 45 days of the expiration date of the WHEAP contract. The Division has the authority, in accordance with State procedures, to reconcile payments and report expenses. Payments shall be used only for current WHEAP contract year expenses.

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147 Revised: August 2025 Appendix A | Agency Guidelines for Handling Sensitive Data General Contracted agencies shall ensure program employees, both internal and subcontracted, shall take reasonable efforts to protect and secure sensitive information. Sensitive data are any information of which the loss, misuse, unauthorized access to, or modification of could adversely affect the HE+ Program, contracted agencies, program employees, and/or customers. Sensitive data and information include, but are not limited to, SSNs and PII meaning information that can directly identify a specific individual, household member, or account-specific information.

For the purposes of the following policy, sensitive data has two tiers.

Tier One sensitive data includes: • SSNs by themselves or in combination with any PII (including date of birth, names, address, phone number, fuel account number and name, and income information) • The combination of date of birth and name without an SSN • WHEAP-related single party checks returned to the local agency

Tier Two sensitive data includes: PII elements that may be needed to complete effective business communications in support of the HE+ programs (name, address, phone number, fuel account information, and income information).

Agencies shall limit the use and exchange of sensitive data to the minimum required to conduct HE+ Program business effectively.

When using sensitive data individually or in quantity, contracted HE+ Program agencies, contractors, and participants shall take reasonable actions to ensure the protection of sensitive program data that are collected, displayed, transferred, stored, analyzed, or destroyed. This appendix identifies minimum requirements that shall be used for equipment, information collected, and methods of transferring sensitive information. Contracted agencies shall have documentation and planned procedures in place for the handling of sensitive data and be able to make them available upon request.

Non-Disclosure Agreement A contracted agency shall not disclose sensitive data to any persons other than those directors, officers, employees, and agents who have a business-related need to have access to such information for the limited purposes of the contract and who have been apprised of, and agree to maintain, the confidential nature of such information in accordance with the terms of the contract.

All staff that have HE+ System access will be prompted to agree to the Conflict of Interest/Non- Disclosure Agreement Form upon gaining access to the HE+ System. For staff that work with WHEAP, but do not have HE+ System access, agencies shall require staff members to sign a Conflict of Interest/Non-Disclosure Agreement. A copy of a Conflict of Interest/Non-Disclosure Form may be requested from the Division. This agreement is valid for the duration of employment with the agency. The contracted agency is responsible for the breach of the contract by any agency staff.

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Revised: August 2025 Desktops Desktops that are used for collecting, displaying, transferring, analyzing, or storing Tier One or Tier Two sensitive data shall apply the following standards: 1. Desktops shall be locked when left unattended by authorized personnel. Re-entry into the desktop shall require a user login and password. 2. An automated screen saver lock shall be enabled after 15 minutes of inactivity. Re-entry into the desktop shall require a user login and password. 3. Hard drives shall be cleansed using at least a seven-pass overwrite procedure (commonly referred to as the Department of Defense (DOD) standard), where the drive is written over electronically to eliminate all data prior to surplus or re-assignment to another user or work area. Contracted agencies shall make available upon request verification that the device has been sanitized meeting industry standards, seven-pass overwrite, degaussing (sanitation based on magnetism), or complete physical destruction of the hard drive media.

Portable Computing Devices Portable computing devices that are used for collecting, displaying, transferring, analyzing, or storing Tier One or Tier Two sensitive data shall apply the following standards: 1. Personally assigned portable computing devices shall have full disk (hard drive) encryption, requiring a login and password. 2. Portable computing devices shall have the boot-up from external or secondary devices disabled. Boot-up shall only be permitted from the hard drive. 3. An automated screen saver lock shall be enabled after 15 minutes of inactivity. Re-entry into the laptop shall require a user login and password. 4. Portable computing devices that are inactive for 15 minutes shall automatically lock. 5. Do not store Tier One sensitive data on shared pool portable computing devices. 6. Hard drives shall be cleansed using at least a seven-pass overwrite procedure, where the drive is written over electronically to eliminate all data prior to surplus or re-assignment to another user or work area. Contracted agencies shall make available upon request verification that the device has been sanitized meeting industry standards, seven-pass overwrite, degaussing (sanitation based on magnetism), or complete physical destruction of the hard drive media.

Portable Media Portable devices used for collecting, displaying, transferring, analyzing, or storing Tier One or Tier Two sensitive data shall apply the following standards: 1. Files that contain Tier One sensitive data shall require a password to open. 2. Media that may contain sensitive information shall be encrypted and require a login and password to access the media prior to file or folder access. 3. Shall be stored in a restricted access location, surrounded by a durable physical barrier that is not portable.

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149 Revised: August 2025 4. Disposal of the media shall require wiping electronic media with at least a seven-pass overwrite of the entire medium, degaussing (sanitation based on magnetism), or complete physical destruction of the medium.

General Electronic File Creation and Storage Tier One sensitive data shall not be used to name files or folders. Faxing or transmitting original or copies of SSN cards, driver’s licenses, identification cards, or any Tier One data is prohibited.

Shared Network Drive Files containing Tier One and Tier Two sensitive data stored on a network drive shall be stored in a secured folder limited to staff that require access to the data.

File Transfer Protocol (FTP) Sites Tier One and Tier Two Sensitive data on FTP sites shall require the following standards: 1. Files require a password to open. 2. The password shall not be stored in the file name, file properties, or other related information files about the file (a.k.a. metadata). 3. Password is to be provided to the end user via phone, email, or other separate method of communication. 4. Sensitive data shall not be stored on an FTP site as a long-term or permanent solution.

Email Agencies shall not email Tier One sensitive data. Agencies may, at their discretion, permit applicants to submit HE+ Applications by email. Agencies allowing email applications shall first encourage application via phone, online, in person, or mail as an alternative to email. Agencies shall be clearly advised that they should not include SSNs on emailed applications, advising the applicant that they will be contacted by the agency for this information. Upon receipt of application materials from applicants or household members by email, the application shall be entered using the date sent as the date of application. The application shall remain “Pending” until all information has been verified. Customer signatures received on a Certification Page received by email, even if name is typed in the signature field, are valid signatures. All other applicable WHEAP eligibility policy requirements remain in effect.

Instant Messaging (Texting, Social Media, Direct Messages, etc.) Agencies shall not send Tier One sensitive data externally via instant messaging platforms. Agencies may, at their discretion, conduct outreach to customers via instant messaging or various social media networks. Agencies shall not include SSNs in any external correspondence.

Hard Copies Storing hard copies: Tier One sensitive data that are printed or physically displayed on media shall: 1. Be stored in a locked access location (key code door, key fob, combination lock, etc.). 2. Meet programmatic requirements for record retention requirements. See specific program policies for requirements.

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Revised: August 2025 3. Be disposed of through complete destruction of the material, including shredding the media or burning the materials.

Tier Two sensitive data that are printed or physically displayed on media shall: 1. Be stored in a restricted access location. 2. Meet programmatic requirements for record retention requirements. See specific program policies for requirements. 3. Be disposed of through complete destruction of the material, including shredding the media or burning the materials.

Hard copies in transit: When transporting hard copies of Tier One and Tier Two sensitive data, the data shall be stored in a location secured by a durable physical barrier requiring a code or key, such as a locking metal file case or lock box. A log shall be maintained of all files being transported from the point of origin to the point of receipt. The log shall not be transported in the same location as the hard copies of sensitive data.

Quality Assurance Contracted agencies shall have procedures established to ensure: 1. Employees are made aware of the policy requirements annually. The agency is responsible for ensuring signers of Conflict of Interest/Non-Disclosure Forms have a full and complete understanding of the HE+ Policies for Handling Sensitive Data. 2. Technology and devices are within the standards set forth by the Policies for Handling Sensitive Data. 3. When scanning (making an electronic copy of) documents for storage, the original hard copy or source data are to be maintained until the scanned document imagery is secured. Original hard copies and source data are to be handled and destroyed in accordance with applicable document retention guidelines. Original hard copies are not required to be retained once scanned into the HE+ System. 4. Documentation is written and maintained for plan of action regarding incident management and data handling. Employees are to immediately notify their supervisor if it is suspected that sensitive data may have been compromised in any way (i.e., loss, theft, unattended media including, but not limited to, personal electronic device(s), desktop computers, and laptops). Incident information to be recorded and retained: a. Date and time of incident b. Location of incident c. Description of what happened to expose the data d. List of potential impacted identities shall be made available upon request in a password-secured document e. Plan of prevention and correction f. Incident information will be password protected in a secured folder on the network drive and restricted to the necessary authorized individuals g. DEHCR shall be notified of any incidents and corrective actions

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151 Revised: August 2025 5. Contracted agencies shall not: a. Scan, photocopy, or retain photo identification of program applicants or household members. b. Scan, photocopy, or retain Social Security cards of program applicants or household members. c. Send or request materials to be sent containing SSNs by public or private mail, text, social media, or instant messaging service.

Definitions contracted agency – An agency that has entered an agreement for program delivery on behalf of the HE+ Program or Wisconsin DOA, DEHCR.

cyber breach – A cyber breach is any security incident in which unauthorized parties access sensitive or confidential information.

degaussing – A method of eliminating data on a storage device, where the drive is subjected to sufficient levels of magnetism to result in destruction of all data on the drive.

desktop – A computer that is intended as a non-portable workstation.

email – An electronic system which is used to exchange messages between individuals through the internet. Agencies emailing customers must place customers’ email addresses in the BCC line.

File Transfer Protocol (FTP) site – An internet site intended to transfer files or folders.

instant messaging – A type of online chat that offers real-time text transmission over the internet.

hard copies – A hard copy is any information printed, written, or displayed on a surface such as paper.

overwrite procedure – A method of eliminating data on a storage device, where the drive is repeatedly written over electronically to eliminate all data.

metadata – Any related information about the file or data.

Personally Identifiable Information (PII) – Any information by itself or combined with additional information that can be used to directly identify a specific individual.

portable computing devices – Any device that is designed as a portable workstation for an individual.

portable media – A drive, disk, or storage device that can be removed from one electronic device and used on another electronic device.

scanning – Making an electronic copy of a physical document.

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163 Revised: August 2025 3.3.2 Counting Income • Added – Ignore first check received when a household receives an extra paycheck from wage income • Removed – Prior month test period that contains an extra check or overtime hours • Removed – Disability Long Term Offset • Added – #7d – Payments reported as “rollover” • Updated – #7g – Changed the age from 70 to 73 and provided further clarification of when withdrawals should or should not be counted • Removed – Annual withdrawals taken each year that are considered recurring income 3.3.5 Self-Employment Income • Added – HE+ System Notes need to be added for when the business ended to verify status of self-employment • Added – SE income losses may not be offset by income reported on a 1099 3.3.5.1 Verification of Income – Self- Employment Income • Added – Example regarding business that started less than a full calendar year ago 3.3.5.2 Use of Self-Generated Income Report Forms • Added – Allow a 1099 be utilized for independent contractors including example Table 3.4 Counted Income Types • Removed – Long Term Disability regarding offset Table 3.5 Deducted Income Types • Added – Ignore Medicare Part C and Part D in addition to Part B Table 3.6 Ignored Income Types • Updated – Assets – Changed the age from 70 to 73 and added information regarding inherited IRA • Added – Lump Sum Payments – Information regarding inherited IRA • Added – Wages and Salaries – Ignore first check received when an applicant receives an extra check from wage income 4.3.4.1 Online Application Statuses • Added – Online application may be voided if customer already received benefits in current program year, including HE+ System Notes 4.3.4.3 Validating Online Applications • Added – SSN requirement • Added – Applications require contact to be made to all individuals who are over the age of 18 and verify if they have or do not have income 4.4.15 Field #9 Residence Address • Added – HE+ System Notes requirement 4.4.27 Household Income • Added – Applications require contact to be made to all individuals who are over the age of 18 and verify if they have or do not have income 4.4.28.7 Annual Fuel Cost • Added – WPPI member utilities • Updated – Clarification on 13 months of usage

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Revised: August 2025 5.1 Introduction • Added – Clarification regarding winter moratorium state statute • Added – Clarification regarding how crisis policy is fluid and may change during the heating season and to follow Informational Transmittal 5.2.1.2 Crisis Assistance Amount • Added – Contacting HE+ Help Desk shall include the hardship the household is experiencing • Removed – Pre-approved range on LIHEAP and PB 5.2.3 Exceptions to the Applicant Contribution Requirement • Added – Clarifying exceptions to include attempts regarding non-WHEAP funding to satisfy the clients contribution 5.3 Crisis Assistance Applications • Added – WPPI member utilities 6.3 General Quality Assurance Agency Responsibilities • Added – If unable to review all required cases, note shall be added to the GQA 6.4 Program Services Quality Assurance Agency Responsibilities • Added – If unable to review the required cases, note shall be added to the PSQA 7.1 Updates to Applicant Information • Updated – Changed title from “Master Record (Not currently Available)” to “Updates to Applicant Information • Removed – References to the Master Record • Updated – Add HE+ System Notes for changes to applicant information 7.3.7 Wrong Vendor Entered on Application • Added – HE+ System Notes requirement 8.2 Payments Sent Directly to the Vendor • Updated – Changed title wording from “Checks” to “Payments” 8.5 Payment Registers • Updated – Changed wording from “Checks” to “Payments” • Added – Vendor ACH payment schedule 9.2.1 General • Updated – Representatives to attend meetings/trainings 9.2.2 Public Information • Updated – Requirements regarding Division website WHEAP page 9.2.3 Outreach • Updated – Reference to Division website WHEAP page on electronic media • Removed – Requirement for the online application 9.2.9 Fraud • Removed – Agency working with local authority • Added – Process for when to contact Division regarding fraud • Added – Clarification for when to utilize an HE+ Repayment Agreement

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Revised: August 2025 Appendix H | Required HE+ System Notes As a best practice, workers processing WHEAP applications shall create HE+ System Notes in the following circumstances: • When a household's annual fuel costs are unusually high or low, to verify that the unusual annual usage amount is not due to a keying error • When a decision was made on an application based on guidance from the HE+ Help Desk • Whenever a worker has phone, email, or mail correspondence with the customer about scheduling an application appointment, the status of a check, or any other inquiries or complaints about the application • When an application is incomplete, to explain what information is missing and why the application is “On Hold”

The table below is an index of the HE+ System Notes requirements that appear throughout the WHEAP Manual. Please note that workers must read each indicated policy in its entirety for full information about the required HE+ System Notes.

Table H1: Program Introduction Subject Policy Note Requirement Hearings 2.8.2 Appeal requests shall be documented in a log and summarized in HE+ System Notes.

Table H2: General Eligibility Rules and Guidelines Subject Policy Note Requirement Application completed after May 15 3.1 Explain why the application was backdated to May 15. Residency 3.2.2 If a case head or household member lives in more than one residence, explain how their primary residence was determined. Residency 3.2.6 If a case head or household member lives in more than one residence, explain how their primary residence was determined. Eligible Non-Citizen 3.2.2.4 Document method used to verify FoodShare or Social Security income. Eligible Non-Citizen 3.2.2.4 Identify the document viewed to verify lawful status in the U.S. SSN Exceptions 3.2.3.3 Explain reason for no SSN and include proper documentation. Religiously Exempt 3.2.3.3.2 Add the ITIN to an HE+ System Note. Household Member Over 60 days Old 3.2.3.3.4 SSN situation must be fully documented in HE+ System Notes. Proof that SSN was applied for should be uploaded to misc. documents; if SSN has not been applied for, include timeline of events that have occurred to date, and next steps. Application must include HE+ System Note from the Division stating that an exception was granted. SSN Override 3.2.3.4 Give reason for the SSN override request. The Division will add HE+ System Notes approving, denying, or asking for more information.

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171 Revised: August 2025 Subject Policy Note Requirement Change SSN Request 3.2.3.5 Explain that the application was first entered with the wrong SSN. When deleting an application because of a wrong SSN, the System Note should include the PID that the application was originally entered under. Student Status 3.2.4 If a student is eligible for WHEAP due to a disability, explain how the individual's disability was verified. Counting Children 3.2.6.1 Document what the applicant stated about child(ren)'s living situation in shared living situations, and how it was determined to include or exclude child(ren). Categorical Eligibility 3.3.1 When a household is over income but is categorically eligible, explain how the categorical eligibility was verified. For FoodShare, include which household members and which months they received FoodShare.

Table H3: Income Types Subject Policy Note Requirement Interest and Dividends 3.3.2 Document in source field or an HE+ System Note each source of interest or dividend income reported (enter all sources as one income entry). Present-Month Income 3.3.2 If the present month is being used as the income test period for an HE+ Application, document the household’s prior month income with an HE+ System Note in addition to uploading documents to verify the prior month income. Self-Employment Income 3.3.5.1 If self-employment income ended prior to the test period, explain this and include the business operation end date. Zero Income 3.3.5.4 When a ZIF is not required because verification of ignored income was used for the required document upload, explain why a ZIF was not completed. Seasonal Workers' Income 3.3.6 Document the information used to determine an individual is a seasonal worker.

Table H4: Application Process Subject Policy Note Requirement Pending App for Zero-Income Interaction 4.1.1 Explain when a zero-income application is “Pending” for interaction with the applicant. Fraud Prevention 4.1.10 Name of the manager/supervisor who reviewed the application of an agency employee, former employee, or relative or family member of an agency employee. HE+ Recertification Form 4.2.3 When a household submits a Recertification Form but does not meet the Recertification Form criteria, document how the full application process was completed. Automated Applications 4.2.4 When a customer contacts the agency with additional information on an automated application, document the information that was updated and requested.

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Revised: August 2025 Subject Policy Note Requirement Phone Applications 4.2.5 Document what additional information was requested. Verification of Information 4.3.2 When the verified application information differs from the customer submitted application, explain the differences. Verification of Information 4.3.2 If information on a current year application differs from application history, explain the differences. Validation of Applicant Data 4.3.3 Document the reason for bypassing system validation functions (MCI, WEFI). Online Application Processing 4.3.4 If verbal notice is provided to the customer of missing information to complete the validation process, document that verbal notice was provided and describe the missing required information. Online Application Processing 4.3.4 If an online application is voided, explain the reason and state when customer contact occurred. Updating Online Statuses 4.3.4.2 If application status is changed, explain the reason and state when the customer was notified. Validating Online Applications 4.3.4.3 When voiding an online application because it is a duplicate, document why the application was voided and when the customer was contacted. Updating an Application Created by Another Agency 4.3.5 Explain the situation when the “ownership” of an application is transferred. Updating an Application Created by Another Agency 4.3.5.1 Explain the document upload, including the method of contact with the customer and the date of contact with the customer. “Withdrawn” Application 4.4.5 Explain the reason for the customer’s withdrawal. Field 7 Housing Type 4.4.13 If the housing type is “Motel or Camper/RV,” provide a full description of the situation. Field 7 Housing Type 4.4.13 Document the reason for selecting the housing type when the residence does not meet the “typical” housing definition. Field 8 Mailing Address 4.4.14 If the mailing address differs from the residence address and is not a PO Box, explain why the two addresses are different. Field 8 Mailing Address 4.4.14 When the HE+ System does not validate the mailing address, an Address Note is required to explain how the address was verified as deliverable by USPS. Field 9 Residence Address 4.4.15 When a residence address returns a message that the address has been processed for another case head, provide documentation of the validity of a second application at the same address. Field 10 Ownership Type: Own or Rent 4.4.16 When an applicant is not able to provide all three data elements for the landlord in field 12, provide the available partial landlord information and explain that all three data elements are not available. Field 12 Living Situation 4.4.18 Documentation of proof of permanent address for applicants who are currently homeless moving to a permanent residence.

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173 Revised: August 2025 Subject Policy Note Requirement Field 13 Is Government Assisted Housing: Rental Assistance 4.4.19 When housing assistance is “yes” and utilities are included in rent, explain which utilities are included in rent. Field 14 Guardian Type: Designated Representation 4.4.20 Document form of verification viewed. When Authorization of Representation is viewed, include duration of authorization. Field 14 Guardian Type: Designated Representation 4.4.20 When a minor child is case head, state who signed the Certification Page.

Table H5: Income Subject Policy Note Requirement Household Income 4.4.27 Provide any necessary clarification about how income was calculated. If the application is incomplete due to missing income documentation, explain what information is missing. Self-Certification for Zero Income Households 4.4.27.2 When self-certification is required because third party verification of ignored income is not available, document attempts made to obtain third party verification. Self-Certification for Zero Income Households 4.4.27.2 Explain any ignored income. Self-Certification for Zero Income Households 4.4.27.2 Explain when an application is pending for customer interaction. Document when a needed customer interaction is completed and include any missing ZIF information. Use of the ZIF 4.4.27.3 Explain any follow-up that was completed because a ZIF was incomplete or needed additional information.

Table H6: Fuel Subject Policy Note Requirement Basic Fuel Page Rules 4.4.28.1 When there is no electricity for a household (there is no relationship with an electric vendor), document why no electric fuel type was entered. Energy Fuel Type 4.4.28.3 When there is no electricity for a household (there is no relationship with an electric vendor), document why no electric fuel type was entered. Non-Heating Energy Costs 4.4.28.12 When there is no electricity for a household (there is no relationship with an electric vendor), document why no electric fuel type was entered. Primary Heating Fuel 4.4.28.2 When selecting “wood or other” for the primary fuel type, identify the primary fuel type if the fuel type is not wood. Energy Fuel Type 4.4.28.3 When selecting “wood or other” for the primary fuel type, identify the primary fuel type if the fuel type is not wood. Payment Method 4.4.28.4 When annual fuel costs are not available and zero is entered for the annual costs, explain why zero costs were entered.

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Revised: August 2025 Subject Policy Note Requirement Payment Method 4.4.28.4 When payment method “Heat and/or non-heating electric is included in rent,” “Separate payment to landlord, mobile home park owner, or no direct account with vendor,” or “do not pay” is selected, document how this information was verified. Annual Fuel Cost 4.4.28.7 When the HE+ System prevents entry of usage over $7,000, explain the likely cause of the high fuel usage. Annual Fuel Cost 4.4.28.7 When less than 12 months of costs are provided, indicate how many months of costs were provided and why 12 months are not available. Annual Fuel Cost 4.4.28.7 If a customer has used multiple deliverable fuel vendors and costs from all vendors are not available, enter available costs and explain why this is not the full annual costs. Annual Fuel Cost 4.4.28.7 If fuel costs are available and "0" is entered to use the proxy amount, explain why "0" was entered. Include the annual costs in notes. Annual Fuel Cost 4.4.28.7 When entering actual fuel costs for a duplex, state if there is a shared meter or not. Annual Fuel Cost 4.4.28.7 Document any discrepancies between the WEFI results and the information entered on the application. Account Name and Household Relationship 4.4.28.8 When selecting “other” as the account holder, explain this individual's relationship to the household. Enter Name on Account 4.4.28.9 When selecting “other” as the account holder, explain this individual's relationship to the household. Shared Meter 4.4.28.10 Explain what additional dwelling the meter is shared with. If this dwelling is a business, select “business use” and state what type of business is on the same meter. Business Use on the Account 4.4.28.11 If business occurring in the home has little impact on the home energy use, document this in a System Note. Business Use on the Account 4.4.28.11 If the business use questions result in a situation that is questionable, indicate the applicant's answers to the test questions. Business Use on the Account 4.4.28.11 Describe the source of income and what test was used to determine business use or no business use. Non-Heating Energy Costs 4.4.28.12 If a household is without an electric burden, provide an explanation. Applicant Signature Date 4.4.29 When a Certification Page is received without a date, explain that the applicant did not date the Certification Page.

Table H7: Emergency Crisis and Prevention Assistance Subject Policy Note Requirement Denials of Eligibility 5.2.1.1 If customer is denied Prevention Assistance, explain customer’s request and the denial. Crisis Assistance Amount 5.2.1.2 Document the vendor minimum payment requirement for the crisis request.

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175 Revised: August 2025 Subject Policy Note Requirement Crisis Eligibility - Additional Guidelines 5.2.3 The reason for the assistance must be included in either an HE+ System Note or the “Customer Request Reason” field. Exceptions to the Applicant Contribution Requirement 5.2.3 Describe the circumstances that justify granting the exception. General WHEAP Agency Responsibilities 5.2.4 If the service date is beyond 48 hours from the request date for emergency services, document when the customer was contacted after the request. General WHEAP Agency Responsibilities 5.2.4 Enter an explanation for each crisis occurrence (in HE+ System Notes or in the “Customer Request Reason” field) of the circumstances of the crisis and how the crisis service will assist the customer. General WHEAP Agency Responsibilities 5.2.4 If the service date is beyond 48 hours from the request date for prevention services, document when the customer was contacted after the request. Crisis Assistance Applications 5.3 Document any discrepancies with the WEFI call. Crisis Assistance Applications 5.3 If Crisis Assistance is being paid on a closed account, explain the reason. Crisis Assistance Applications 5.3 Explain the circumstances of the crisis and how the crisis service will assist the customer in an HE+ System Note or in the “Customer Request Reason” field.

Table H8: Quality Assurance Subject Policy Note Requirement GQA Agency Responsibilities 6.3 At the time of the review, add an HE+ System Note to each general case, identifying it as having been reviewed. GQA Agency Responsibilities 6.3 Indicate why an application is being corrected. PSQA Agency Responsibilities 6.4 At the time of the review, add an HE+ System Note to each HE+ Program Services case, identifying it as having been reviewed. PSQA Agency Responsibilities 6.4 Indicate why an application is being corrected.

Table H9: Errors, Mistakes, Corrections Subject Policy Note Requirement Updates to Applicant Information 7.1 Explain any changes made to the application, including how the information was learned and/or verified. Change in Address 7.1.1 When updating the mailing address prior to an extraction of an application, explain the move/change of physical address.

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Revised: August 2025 Subject Policy Note Requirement Updates to Unextracted Applications 7.3.3 Explain why a “Submitted” application was changed to “Pending.” Denied in Error and Extracted (Reinstate the Application) 7.3.4 Explain the error. Errors Which do not Affect the Benefit(s) 7.3.6.1 Describe the corrected information and the impact to the application. Errors Which May Affect the Eligibility/Benefit(s) 7.3.6.2 When neither benefit is affected by more than $30, provide the correct information and explain the benefit calculation results. Errors Which May Affect the Eligibility/Benefit(s) 7.3.6.2 If either or both benefits are affected by more than $30, explain why the application is being corrected. Errors Which May Affect the Eligibility/Benefit(s) 7.3.6.2 For overpayments made to bulk fuel vendors, if the correction can be made before the vendor has delivered the fuel, document when vendor was contacted and verified that the customer balance is sufficient to cover the overpayment. Errors Which May Affect the Eligibility/Benefit(s) 7.3.6.2 Explain how it was determined who is responsible to pay back overpayments and how vendor was notified. Errors Which Affect Wx 7.3.6.3 Fully document the situation. Deceased Individual 7.3.8 Indicate how the agency learned of this information. Deceased Individual 7.3.8 If deceased status is changed to not deceased, document the change of the status. Deceased Individual 7.3.8 If a paper application is received with a household member who is now listed as deceased, document that an individual listed on the application is now marked deceased. Automated Applications: Change in Household Composition or Income 7.4.2 Explain what was changed (household members or income) and why. Automated Applications: Change in the Address (Moved) 7.4.3 Document why the fuel account was still active during the automated application process. Explain the household changes that occurred. Crisis Paid to Wrong Account 7.5.2 Indicate the date the request was made to the vendor to transfer the benefits.

(py2026)Wisconsin Home Energy Assistance Program (WHEAP) Manual, Program Year 2026#

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