Facing Challenges
As a new federal program tasked with expediting benefits during a pandemic, OCS and grant recipients faced multiple barriers and challenges in implementing and administering the program. From issues related to bundled billing, moratoria expirations, and plumbing repairs. OCS worked with partners to mitigate challenges and overcome barriers to serve households in need across the country.
Differences Between Water Assistance and Energy Assistance
As discussed above, LIHWAP’s authorizing legislation instructed that the program should use the processes, procedures, policies, and systems of existing assistance programs serving households with low incomes. OCS relied on LIHEAP’s infrastructure to guide program development given the program’s shared aim to provide utility assistance. While LIHEAP and LIHWAP provide similar services and meet similar household needs, there are significant differences in the water and energy landscape as well as differences in the programs’ authorizing language that created challenges during the implementation and administration of LIHWAP. For example, there are far more water utility companies than home energy providers. Compared to 50,000[41] water utility companies, there are approximately 2,022 natural gas delivery companies[42], 3,000 electric distribution companies[43], and 4,000 propane companies.[44]
There are far more water utility companies than home energy providers.
Water Utility Companies
Natural Gas Delivery Companies
Electric Distribution Companies
Propane Companies
Standing Up a New Program
LIHWAP is the first-ever federal water bill assistance program, and as such, a significant amount of work had to be done upfront to get the program running before benefits could begin to go out to households. Specific knowledge related to the water landscape across the US, and capacity to administer a water affordability program needed to be built among federal, state, and community agencies, which contributed to the need for additional time to stand up the program. At the federal level, much work went into ensuring that funding was allocated equitably and appropriately, as well as structuring and hiring a team that had the content and methodological expertise necessary for supporting LIHWAP grant recipients. At the grant recipient level, time was dedicated to establishing agreements with water utilities and to adapting processes for issuing payments. Some grant recipients were able to quickly adapt their administrative process to include LIHWAP, while others (particularly smaller grant recipients with lower overall administrative capacity) required more time and training and technical assistance to develop and implement protocols for their individual LIHWAP programs.
Bundled Bills
Many utilities bundle multiple services on a single household bill. For example, trash, sewer, electricity, and water may all appear on a single bill. Per the LIHWAP authorizing legislation, grant recipients may only make payments for the water and/or wastewater portions of the bill. Many larger utilities have been able to program their IT systems to apply LIHWAP benefits only to the appropriate section(s) of the bill. However, some utilities found it too time-consuming, costly, and challenging to manually split the charges to make sure only water and wastewater were paid for with LIHWAP funds.
To mitigate this challenge and better assist households served by utilities that were unable to split the charges or reticent to reconnect water services without payment for other services (e.g., trash), OCS examined what other federal programs could be leveraged to fully meet households’ needs. Authorized by CAA and ARP, the Emergency Rental Assistance Program (ERA) provided over $46 billion to assist rental households that were unable to pay rent or utilities. ERA funds were provided directly to states, U.S. territories, local governments, and tribes.[45] As ERA funds could be used for utilities on bundled bills that LIHWAP could not pay for, OCS encouraged LIHWAP grant recipients to coordinate with ERA to braid resources to provide comprehensive service to households.
Household Plumbing
Many grant recipients reported challenges regarding the need for resources to support minor household plumbing repairs. These repairs were needed to ensure households could afford access to water and wastewater services. A minor plumbing issue, such as a running toilet or dripping faucet can exacerbate water affordability for households with low incomes. For example, some households that have had water services disconnected for nonpayment of arrearages accumulated in part due to plumbing issues, may require minor repairs (e.g., the repair of a dripping faucet leaking pipes) to make their water affordable. Minor repairs can help make water more affordable in the long-run for households.
Since LIHWAP funds could not be used for payments to contractors or payments made directly to households for minor plumbing repairs, OCS issued guidance to encourage LIHWAP grant recipients to leverage other available resources to support small infrastructure needs for families receiving a LIHWAP benefit, including Community Services Block Grant funds.[46]
Moratoria
In the beginning of COVID-19, many states and localities enacted moratoria in which households’ water and wastewater services could not be disconnected for lack of payment. Individuals with low incomes were already having to make difficult choices between paying for paying their water bill or paying for other vital goods and services such as medicine, groceries, and other household items. Once the moratoria were no longer in place, many households began applying for LIHWAP funding to pay their past due balances and found that their water bill exceeded the maximum benefit amount. Additionally, in some areas, the end of moratoria led to an influx of applications and higher levels of need later into the program’s implementation when program funds were dwindling. LIHWAP federal staff provided comprehensive technical assistance to grant recipients to demonstrate how LIHWAP could be used to increase the maximum benefit amounts to address large balances due to moratoria.