With limited exceptions (see sections on Social Security Numbers and Citizenship), there are no LIHEAP regulations or guidelines regarding what identity information states can request from applicants. It is standard practice for states to request the following information, at a minimum, for the LIHEAP applicant as well as all household members: full name, mailing and street addresses, telephone number, county of residence, date of birth, gender, and Social Security Number (SSN).
However, some states ask for less information and some ask for more. For example, some states ask an applicant's race, age, primary language, education, employment and marital status. They often inquire as to the relationship of other household members to the applicant. Some ask whether anyone in the household is disabled, is a student or veteran, or receives other program benefits, such as SNAP or TANF. Examples of LIHEAP applications are found here.
Regarding provision of SSNs, LIHEAP Information Memorandum 2010-6, issued by the Division of Energy Assistance on May 5, 2010, says that HHS lacks "the authority to require States to mandate provision of SSNs, (but) States do have the authority under the Privacy Act to choose to require the provision of SSNs." In the same memorandum, HHS advised states that they may use Social Security Numbers to validate that individuals and households receiving LIHEAP benefits are eligible and in need of the services the program provides.
HHS further advised that:
- States may require that any individual applying for LIHEAP disclose his/her SSN, as part of the application, to validate identity and as a condition for the receipt of benefits.
- States may require the SSNs of all household members reported in the LIHEAP application in order to qualify the household for any LIHEAP benefit.
- States may deny assistance to individuals and households upon a refusal to provide SSNs.
According to research from the LIHEAP Clearinghouse, the majority of states have historically required or requested SSNs from the applicant and all household members. As a result of IM 2010-6, more states began requiring SSNs for the applicant and all household members in order to enhance program integrity.
In general, the more client information states obtain, the better they are able to:
- Cross-check eligibility information on questionable applications
- Provide client education and referral regarding other human services programs in order to fulfill outreach and coordination requirements of the LIHEAP statute
- Target outreach, benefits, and other program services based on client needs, e.g., special services to the elderly or disabled, or high-energy-burden households
- Gather and maintain client demographics for statistical, reporting and research purposes