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PY26 WHEAP Manual

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.