Best Practices
State, territorial, and tribal grant recipients designed their programs to meet the unique needs of the communities they serve. Despite variations in program implementation and structure, best practices for effectively and efficiently serving households have emerged across the country. Key best practices are documented below. When appropriate and feasible, OCS has and will continue to encourage grant recipients to implement these strategies.
Adjusting benefit levels for households
Grant recipients have the flexibility to determine their own minimum and maximum benefit payment amounts according to local need. When LIHWAP began, the median maximum benefit amount for state grant recipients, as indicated on implementation plans, was $1,500, while the median amount for tribes was $700. As administering agencies received applicant water bills and learned more about the cost of water and wastewater in their area, these payment limits were adjusted to serve households more effectively.
After the utility disconnection moratoria enacted during the COVID-19 pandemic ended, many households with low incomes across the country were left with very large past due bills. In several cases, grant recipients raised maximum payment limits to pay the total amounts of these water bills to prevent disconnection of service. Minimum payment limits were also adjusted to ensure households served by systems that had not fallen under disconnection moratoria received the support they needed to prevent service disconnection. Some of these households did not accumulate large past due balances but still needed assistance paying their relatively smaller bills to reconnect or prevent disconnection of services.
Notable example from Texas:
The Texas Department of Housing and Community Affairs (TDHCA) first set a LIHWAP maximum benefit payment amount of $600. As the state received applications, it became clear that there were households at risk of disconnection with past due amounts much higher than $600. TDHCA removed their maximum benefit limit to pay the entire bill amount for these households.
- Recognizing households at risk with higher past due amounts, TDHCA removed the limit to pay entire bill amounts.
- This change helped restore or prevent disconnection for 12,004 households in Texas.
- No maximum payment limit enables assistance for households significantly behind, in crisis, or facing high bills due to infrastructure issues they can't afford to repair.[36]
Notable example from Illinois:
The Illinois Department of Commerce and Economic Opportunity (Illinois DCEO) set an initial LIHWAP minimum payment of $250 to prioritize reconnecting those with large past due bills. However, the state found that most applicants with large past due bills lived in Chicago, while applicants in the rest of the state had much lower past due amounts. This was especially true in rural areas, where local agencies noticed that many income-eligible households were not able to receive LIHWAP benefits because their water and wastewater bills were lower than the state’s minimum payment of $250.
- In rural areas, smaller water providers continued payments or disconnections, making eligible households unable to receive benefits.
- Some faced disconnection notices for bills as low as $20.
- In response to concerns raised by local agencies, DCEO removed the minimum payment policy in July 2022 for more equitable service to rural households.
Allowing for Credits on Beneficiary Accounts
Providing credits on water accounts has proven effective in reaching more households and promoting long-term water affordability. In 2023, OCS permitted leaving credits on water and wastewater provider accounts, aligning with LIHWAP's priority of rate reduction. Grant recipients used a benefit matrix to determine credit amounts based on factors like household income, size, and water cost. This approach allowed for equitable service, addressing variations in current and past due bill amounts among income-eligible households with diverse water vendors and disconnection policies.
Notable example from Indiana:
During the first year of LIHWAP, the Indiana Housing and Community Development Authority (IHCDA) prioritized providing benefits to households that were disconnected or at risk of being disconnected because of past due water or wastewater bills. In reviewing this first year, IHCDA noticed that many eligible households that applied to LIHWAP had not received a benefit because they were current on their water bills. Indiana’s local agencies informed IHCDA that water and wastewater provider payment and disconnection policies varied greatly across Indiana. For example, some households may be disconnected after one month of nonpayment, while others may not be disconnected for several months. In many cases, households facing strict disconnection policies prioritized paying for water over other necessities that may be foregone. LIHWAP was not providing financial relief to these households. To serve more households, Indiana began using a benefit matrix to ensure that all income eligible applicants, regardless of if they were at risk of disconnection, would receive a benefit to pay for past or current bills. For households with no past due amounts, the benefit matrix resulted in amounts that left credits on their accounts and provided an equitable and useful amount of assistance, regardless of their providers’ policies.
Data Matching
Data matching, the process of identifying applicants who may be eligible for LIHWAP through other existing databases, has proven to be an effective strategy to expedite assistance to households. Grant recipients can work within their agency, with other agencies, or with water and wastewater vendors to identify eligible applicants by securely sharing eligibility and water need data. Grant recipients have approached data matching in different ways; however, overall, the practice allows for more effective outreach, reduces benefits processing time, and increases households served.
Notable example from Puerto Rico:
LIHWAP’s income eligibility requirements align with several existing low-income programs, such as LIHEAP, TANF, and SNAP. The Puerto Rico Departamento de la Familia, the LIHWAP grant recipient, also administers the Nutrition Assistance Program (NAP)[37] , which also has the same income requirements as LIHWAP.
- Streamlined application: If a household receives these benefits, they are automatically income eligible for LIHWAP.
- Puerto Rico used data matching to identify NAP recipients with past due bills, automatically paying LIHWAP benefits to the water provider.
- This approach rapidly provided over $4.5 million in LIHWAP benefits to 11,261 households in just five months.
- OCS requires proof of water burden, usually verified by water bills, that can also be gathered from water vendor records through data sharing.
Notable example from Virginia:
The Virginia Department of Social Services (VDSS) administers both LIHEAP and LIHWAP. The state has used data matching processes to work with 85 water and wastewater vendors to determine categorical eligibility and conduct outreach to households.
- Vendors signed agreements to provide lists of customers with past due bills to VDSS.
- VDSS cross-referenced with past LIHEAP recipients, sending them a text message with application information.
- Result: Virginia provided over $9.5 million in LIHWAP benefits to over 13,000 households in the first three months of program operation.
Collaborative Outreach
LIHWAP’s novelty as the first-ever federal water bill payment assistance program meant that grant recipients had to be thorough in their outreach approaches. When programs opened, many households were unfamiliar with LIHWAP and grant recipients had to develop creative strategies and partnerships with local agencies, vendors, and other organizations to reach eligible households.
Notable example from Michigan:
The Michigan Department of Health and Human Services (MDHHS) sent text messages directly to nearly 600,000 households encouraging them to apply for LIHWAP.
- Messages began with a simple question about being behind on water bills, followed by informative prompts.
- Geographically tailored messages directed applicants to local agencies, collaborating with MDHHS.
- Result: Michigan increased households served by 339%, from 4,609 in FY2022 to 20,218 by June 30, 2023.
Notable example from Pennsylvania:
The Pennsylvania Department of Human Services (DHS) leveraged state legislators to help spread the word about LIHWAP early in their program’s administration.
- Detailed program information shared with the Office of Legislative Affairs for reference during public inquiries.
- Legislators hosted town halls, listening sessions, and shared program details on social media.
- Pennsylvania ensured client advocates and interest groups were informed, leveraging their networks for program outreach.
Notable example from the Lumbee Tribe of North Carolina:
LIHWAP staff at the Lumbee Tribe of North Carolina worked collaboratively with the tribe’s housing, support services, and energy program departments to reach households.
- These departments identified hard-to-reach members and targeted areas for outreach through community meetings and churches.
- Outreach teams visited communities, and staff traveled weekly to assist those unable to reach the LIHWAP office.
- Partnership with the local water provider helped promote LIHWAP to tribal members facing disconnection.
Implementing Program Funding Flexibilities
To address challenges in areas without public water systems or treatment works, LIHWAP examined allowable fund uses, including providing bottled water, septic tank services, and filling water cisterns. Specific guidance was provided to grant recipients on when these flexibilities could be employed:
Bottled Water:
- LIHWAP funds can be used to supply bottled water in areas lacking clean water, such as those with lead contamination, remote communities, or areas affected by disasters.
- Water bottles can be delivered or picked up.
Water Cisterns:
- Grant recipients can use funds to fill water cisterns for households not connected to a drinking water system, especially in remote areas.
- Cisterns hold a household's water supply and are typically refilled semi-regularly, depending on rainfall.
Septic Tanks:
- LIHWAP funds can cover septic tank pumping in areas without wastewater (sewer) systems, with payments made directly to a vendor.
- This flexibility is crucial for many rural areas relying on septic tanks for wastewater treatment.
Notable example from San Carlos Apache:
Many members of the San Carlos Apache Tribe of Arizona do not have access to clean, piped drinking water. The Tribe therefore utilizes LIHWAP flexibilities to provide bottled water to eligible households on a monthly basis.
- San Carlos Apache has formal agreement with a local supermarket allowing eligible households to receive ten cases of water monthly.
- Tribe offers delivery for beneficiaries unable to pick up water bottles themselves.
- In FY22, 1,697 households benefited from San Carlos Apache's LIHWAP bottled water program.
Notable example from Seneca Nation:
Low-income households in rural areas not serviced by wastewater (sewer) treatment systems often must use septic tanks. Septic tanks typically must be serviced, or pumped, every three to five years. In administering LIHWAP, the Seneca Nation of Indians of New York found that some tribal households using septic tanks were behind on tank maintenance because they could not afford tank servicing.
- Seneca Nation identified tribal households struggling with septic tank maintenance due to affordability.
- Contracted with a local company to provide septic tank servicing for households with high need.
Collaboration with Local Agencies
Long before LIHWAP was created state grant recipients used networks of subcontracted local agencies to administer various anti-poverty programs (such as LIHEAP and the Community Services Block Grant). These local agencies partner with states on outreach, administration, intake, and eligibility determination . Collaborating with this strong network of partners was helpful for setting up LIHWAP in many states. States worked with these local agencies to design state plans as well as develop and implement outreach strategies. Most importantly for this new program, local agencies worked closely with states to identify problems and potential program improvements in real time while administering the program on the ground level.
Notable example from Kentucky:
The Kentucky Department for Community Based Services (DCBS) contracts with 23 local agencies, called Community Action Agencies (CAAs), across all 120 counties of the state to administer a variety of anti-poverty and self-sufficiency programs.
- Kentucky leveraged existing CAA network for LIHWAP implementation, holding weekly training calls for feedback and program changes.
- CAAs used state training materials to educate water utilities on LIHWAP benefits.
- Kentucky rapidly served 38,901 households in seven months, becoming the first state to exhaust LIHWAP funding.
- Funding restored 2,121 water connections, prevented 23,365 water disconnections, and provided rate reduction for 19,322 households.[38]
- Community Action Agencies viewed LIHWAP as a tool to strengthen their existing services, recognizing the vital role of reliable water systems in community well-being.
Redeeming Property Liens
Several states have struggled to provide benefits to households with liens on their property because of past due water and wastewater bills. These liens were placed on properties before the availability of LIHWAP assistance. In all states, households served by publicly owned water and wastewater utilities are subject to having liens placed on their property for delinquent bills.[39] Liens due in part or in full to delinquent water bills can be sold at auction sales and potentially lead to loss of home ownership, and liens can be placed on homes for past due amounts as low as a few hundred dollars.
Though water liens are allowed by every state, laws vary by municipality, and they are more common in some states than others. A few LIHWAP administrating agencies have been successful in working with municipalities and applicants to redeem property liens because of past due water and wastewater bills and put households a step closer to restoring their property rights.
Notable example from New Jersey:
When New Jersey Department of Community Affairs (DCA) began processing LIHWAP applications, they found that many applicants had liens placed on their homes that had already been sold to lienholders because of past due wastewater bills. Beyond issuing LIHWAP benefits to households in this situation, New Jersey DCA became involved in the process of releasing the liens once payments were made.
- Negotiated lien release costs with tax collectors and paid entire amounts below New Jersey's $5,000 maximum benefit.
- Collaborated with NJSHARES to cover amounts exceeding $5,000 for lien release.
- Efforts led to legislative guidance preventing liens for households applying for LIHWAP, with tax collectors accessing the LIHWAP portal for verification.
- Liens couldn't be placed if providers hadn't signed a vendor agreement, ensuring eligibility for LIHWAP benefits.[40]