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HHS/OCS Announces Revisions to Proposed Performance Measures

January 3, 2014 — In mid-December, the US Department of Health and Human Services' Office of Community Services (OCS) distributed a letter to LIHEAP grantees with updated information regarding the establishment of new performance measures. A significant development was that a few data elements originally proposed as mandatory in June are now set to be optional.

The formal process for implementing the new performance measures began in June 2013, when OCS published a notice in the Federal Register about supplementary data reporting by state grantees. After taking public comments for 60 days, OCS reviewed the comments and made some modifications to the original proposal.

In its December 2013 letter, the OCS said public comments raised concerns regarding the relevance and usefulness of the new data; how the burden of collecting the data would use resources that traditionally went to recipient benefits; and the question of whether quality data could be collected from a mobile population that uses multiple energy sources/vendors.

Based on the feedback it received, OCS made the following modifications to the original listing in the Federal Register:

  • Some data elements that were originally mandatory will be optional, including a few that were originally required for the "energy burden reduction" measure. Specifically, the data related to household utility consumption, along with supplemental fuel and air conditioning expenditure and consumption data, will be optional. OCS will encourage grantees to collect this information to identify best practices and strategies.
  • The "energy burden reduction" measure itself will now be calculated using two indices, an Energy Burden Index and a Benefit Targeting Index. OCS says this represents a "more robust measure" than the original proposal.
  • Development of best sampling practices and procedures to help grantees collect high quality data with the least amount of burden.
  • Removal of the term "crisis" from the names of proposed measures in order to not confuse them with grantees' LIHEAP crisis components.
  • Analysis has confirmed a strong correlation between residential energy expenditure and home energy burden. This means no statistical modeling is necessary to extrapolate to the home heating and cooling expenditure level.
  • Commitment to provide ongoing technical assistance to help grantees collect better information about their clients and home energy needs.

The letter also detailed the annual data OCS will seek to collect and synthesize to create the following performance measures (also see the table below):

  • Benefit Targeting Index for High Burden Households - measures the extent to which the highest benefits are provided to households with the highest energy burden;
  • Energy Burden Reduction Index for High Burden Households - measures the extent to which LIHEAP benefits are adequate to deliver the same energy burden reduction to high burden recipient households as to low and moderate burden households;
  • Prevention of Loss of Home Energy Services - the unduplicated count of households where LIHEAP prevented the loss of utility services; and
  • Restoration of Home Energy Services - the unduplicated count of households where LIHEAP restored utility services.

OCS also announced in the letter that it will hold a webinar on January 14, 2014, about these performance measures (see this page for details), and it encourages grantees and other stakeholders to submit questions in advance to be addressed during the webinar. Following the webinar and the incorporation of any further revisions that may be necessary, OCS will publish a second Federal Register notice that will allow for 30 days of public comments. These comments will be sent directly to the Office of Management and Budget, which is the agency that ultimately needs to approve the new data collection.

For more background on the original catalyst for developing new performance measures, please see the lead article in the LIHEAP Clearinghouse's June 20013 newsletter.

Proposed Measure
Data Elements

Benefit Targeting Index and Energy Burden Reduction Index

For all bill-payment households, by main heating fuel and for all high energy burden households (top 25 percent), by main heating fuel

  • Average income
  • Average benefit
  • Annual cost of main heating fuel
  • Annual electricity cost
  • Annual consumption of main heating fuel (optional)
  • Annual consumption of electricity (optional)

Prevention of Loss of Home Energy Services (unduplicated number of households)

  • Number of households where utility service termination was prevented
  • Number of households where a fuel delivery prevented loss of service
  • Number of households where heating or cooling equipment was repaired or replaced prior to failure

Restoration of Home Energy Services

  • Number of households where utility service was restored
  • Number of households where a fuel delivery was made to a home that was out of fuel
  • Number of households where broken hearing or cooling equipment was fixed

Source: OCS, "Dear Colleague Letter," Dec. 17, 2013

Source: US Department of Health and Human Services/Administration for Children and Families/Office of Community Services