During the public comment period on the proposed rule to make specific living arrangements eligible for a $1 Home Energy Assistance Program (HEAP) benefit, the Office of Temporary and Disability Assistance (OTDA) received numerous comments, almost all of which were very supportive of this proposal.

Comment: Approximately 200 comments were received urging the OTDA to adopt this proposed rule because in conjunction with the proposed amendments to 18 NYCRR § 387.16, it would result in an increase in food stamp (FS) benefits for FS eligible individuals living in group homes.

Response: The OTDA agrees with these comments in support of the proposed rule.

Comment: One commenter supported the change to maximize FS benefits but expressed concern about the administrative burden on the local districts and the HEAP alternative certifiers in processing $1 HEAP benefits for households not in receipt of FS benefits.

Specifically, the commenter was concerned with the following issues:

• The administrative burden imposed on HEAP certifiers if a large number of HEAP applications are received.

• The requirement for the HEAP unit to conduct a full certification for each $1.00 HEAP case.

• The requirement for the HEAP unit to issue $1 HEAP benefits to FS households that are determined eligible for FS benefits after the HEAP season has opened.

• The impact that this rule will have on regular HEAP processing and the possible insufficiency of HEAP administrative funds.

Response: The OTDA recognizes the commenter's concerns regarding the HEAP processing issues. The OTDA has implemented systems support to lessen the administrative burden and has provided training to local certifiers on processing the $1 HEAP benefits for households not in receipt of assistance.

The OTDA does not expect a significant number of applicants in this new $1 HEAP category. Consequently, the impact on local certifiers is not expected to be significant and should not create any disruption in the overall processing of HEAP. Although these applicants must file for benefits in the same manner as any other household, the small volume expected should be manageable. The OTDA will review the process after this current HEAP season to determine if any modifications need to be made.

If a household does not receive FS benefits and applies for a $1 HEAP benefit, a full certification process for HEAP will need to be done. However, as noted above, the OTDA does not anticipate that the number of applications will be significant.

If a household is found eligible for FS benefits and the $1 HEAP benefit after the HEAP season has opened, the $1.00 HEAP benefit will need to be authorized; however, it is up to each district to determine which unit within that district will do this.

HEAP administrative funds are limited by the federal Low-Income Home Energy Assistance Program statute to 10% of the total federal allocation. The OTDA bases local district allocations on the number of applications processed, weighted by category. Since funds are limited, the OTDA cannot guarantee full reimbursement of all administrative costs associated with HEAP, but makes every attempt to provide as much funding as possible, given the amounts available.