With limited exceptions, there are no LIHEAP regulations or guidelines regarding what identity information grantees can request from applicants. It is common practice for grantees to request some combination of the following information for the LIHEAP applicant as well as all household members: full name, mailing and street addresses, telephone number, date of birth, gender, and Social Security Number (SSN). Tribes also frequently request documentation proving a relationship to the tribe, such as proof of tribal enrollment.
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 grantees 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:
- Grantees 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.
- Grantees may require the SSNs of all household members reported in the LIHEAP application in order to qualify the household for any LIHEAP benefit.
- Grantees may deny assistance to individuals and households upon a refusal to provide SSNs.
In 2012, the LIHEAP Clearinghouse conducted a survey of 22 tribal grantees as part of its work with the LIHEAP Program Integrity Working Group. Its results on how tribes use SSNs for their LIHEAP can be found here.
In general, the more client information grantees 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.
For more information about the use of SSNs and household identity, please see "Developing Tribal LIHEAP Programs," a presentation given by HHS representatives at the 2012 National Energy and Utility Affordable Conference. The portion talking about SSNs is in the Program Integrity section, which starts on slide 41.