18 MAC Pt. 16, R. 16.1
Low-Income Home Energy Assistance Program (LIHEAP) State Plan
Cite as 18 Miss. Admin. Code Pt. 16, R. 16.1
Low-Income Home Energy Assistance Program (LIHEAP) State Plan
Source: Miss Code Annotated 43-1-2.
LOW-INCOME HOME ENERGY ASSISTANCE PROGRAM (LIHEAP) - FINAL
DETAILED MODEL PLAN
PUBLIC LAW 97-35, AS AMENDED
FISCAL YEAR (FY) 2024
GRANTEE STATE OF MISSISSIPPI
EIN:
64-6000807
ADDRESS MISSISSIPPI DEPARTMENT OF HUMAN SERVICES
DIVISION OF COMMUNITY SERVICES
POST OFFICE BOX 352
JACKSON, MISSISSIPPI 39205
NAME OF LIHEAP COORDINATOR: Tina Ruffin
E MAIL:
Tina.Ruffin@mdhs.ms.gov
TELEPHONE: (601) 359-4768
FAX: (601) 359-4370
PLEASE CHECK ONE: TRIBE
STATE
Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Washington, DC 20447
THE PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13)
Use of this model plan is optional. However, the information requested is required in order to receive a Low Income Home Energy Assistance
Program (LIHEAP) grant in years in which the grantee is not permitted to file an abbreviated plan. Public reporting burden for this collection of
information is estimated to average 1 hour per response, including the time for reviewing instructions, gathering and maintaining the data needed,
and reviewing the collection of information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number.
GRANTEE Mississippi
FFY 24
Section 1
Program Components, 2605(a), 2605(b)(1) – Assurance 1, 2605(c)(1)(C)
1.1
Check which components you will operate under the LIHEAP program. (Note: You must
provide information for each component designated here as requested elsewhere in this
plan.)
Dates of Operation
Heating assistance
Start date:
October 1
End date: April 30
Cooling assistance
Start date:
May 1
End date: September 30
Crisis assistance
Start date:
October 1 End date: September 30
Weatherization assistance
Start date:
End date:
Estimated Funding Allocation, 2604(c), 2605(k)(1), 2605(b)(9), 2605(b)(16) – Assurances 9
and 16
1.2
Estimate what amount of available LIHEAP funds will be used for each component that
you will operate: The total of all percentages must add up to 100%.
45 % heating assistance
40 % cooling assistance
5 % crisis assistance
0 % weatherization assistance
00 % carryover to the following Federal fiscal year
10 % administrative and planning costs
0 % services to reduce home energy needs including needs assessment (Assurance 16)
00 % used to develop and implement leveraging activities
100_ % TOTAL
GRANTEE Mississippi
FFY 24
Alternate Use of Crisis Assistance Funds, 2605(c)(1)(C)
1.3
The funds reserved for winter crisis assistance that have not been expended by March 15
will be reprogrammed to:
Heating assistance
Weatherization assistance
Cooling assistance
Other (specify): _______________________________
Categorical Eligibility, 2605(b)(2)(A) – Assurance 2, 2605(c)(1)(A), 2605(b)(8A) –
Assurance 8
1.4
Do you consider households categorically eligible if one household member receives one
of the following categories of benefits in the left column below?
Yes
No
1.5
Do you automatically enroll households without a direct annual application?
Yes
No -- If yes, explain:
1.6
How do you ensure there is no difference in the treatment of categorically eligible
households from those not receiving other public assistance when determining eligibility
and benefit amounts?
The benefit matrix determines benefit amounts and does not consider categorically eligible
households.
Heating
Cooling
Crisis
Weatherization
SNAP
TANF
SSI
Means-tested
veteran’s
program
Other (Specify):
______________
______________
GRANTEE Mississippi
FFY 24
SNAP Nominal Payments
1.7a
Do you allocate LIHEAP funds toward a nominal payment for SNAP households?
Yes
No
If you answered “Yes” to question 1.7a, you must provide a response to questions 1.7b,
1.7c, and 1.7d.
1.7b Amount of Minimal Assistance: $___________
1.7c Frequency of Assistance:
Once per year
Once every five years
Other (describe): ____________________________
1.7d How do you confirm that the household receiving a nominal payment has an energy cost
or need?
Determination of Eligibility – Countable Income
1.8
In determining a household’s income eligibility for LIHEAP, do you use gross income or
net income?
Gross Income
Net Income
1.9 Select all of the applicable forms of countable income used to determine a household’s
income eligibility for LIHEAP.
Wages
Self-employment income
Contract income
Payments from mortgage or sales contracts
Unemployment Insurance
Strike pay
GRANTEE Mississippi
FFY 24
Social Security Administration (SSA) benefits
Including MediCare deduction
Excluding MediCare deduction
Supplemental Security Income (SSI)
Retirement / pension benefits
General Assistance benefits
Temporary Assistance for Needy Families (TANF) benefits
Supplemental Nutrition Assistance Program (SNAP) benefits
Women, Infants, and Children Supplemental Nutrition Program (WIC) benefits
Loans that need to be repaid
Cash gifts
Savings account balance
One-time lump-sum payments, such as rebates/credits, winnings from lotteries, refund
deposits, etc.
Jury duty compensation
Rental income
Income from employment through Workforce Investment Act (WIA)
Income from work study programs
Alimony
Child support
Interest, dividends, or royalties
Commissions
Legal settlements
Insurance payments made directly to the insured
Insurance payments made specifically for the repayment of a bill, debt, or estimate
GRANTEE Mississippi
FFY 24
Veterans Administration (VA) benefits
Earned income of a child under the age of 18
Balance of retirement, pension, or annuity accounts where funds cannot be withdrawn
without a penalty.
Income tax refunds
Stipends from senior companion programs, such as VISTA
Funds received by household for the care of a foster child
Ameri-Corp Program payments for living allowances, earnings, and in-kind aid.
Reimbursements (for mileage, gas, lodging, meals, etc.)
Other
GRANTEE Mississippi
FFY 24
Section 2 - HEATING ASSISTANCE
Eligibility, 2605(b)(2) – Assurance 2
2.1
Designate the income eligibility threshold used for the heating component:
FY 2023 state’s median income ____60_____% for all Household sizes
2.2
Do you have additional eligibility requirements for HEATING ASSISTANCE?
Yes
No
2.3
Check the appropriate boxes below and describe the policies for each.
Yes
No
âš« Do you require an assets test?
âš« Do you have additional/differing eligibility policies for:
•
Renters?
•
Renters living in subsidized housing?
•
Renters with utilities included in the rent?
âš« Do you give priority in eligibility to:
•
Elderly?
•
Disabled?
•
Young children?
•
Households with high energy burdens?
•
Other?
Explanations of policies for each “yes’ checked above:
See Eligibility and Benefit Determination Attachment.
The applicant should provide either a copy of their lease; a notarized statement from the
landlord detailing the heating/cooling arrangement with the client; or contract with the
landlord that verifies the heating/cooling arrangement that the landlord has with the
GRANTEE Mississippi
FFY 24
household. Persons/households residing in public/subsidized housing dwelling unless their
rent/mortgage includes utilities and they are not being billed separately for energy cost.
Determination of Benefits, 2605(b)(5) – Assurance 5, 2605(c)(1)(B)
2.4
Describe how you prioritize the provision of heating assistance to vulnerable households,
e.g., benefit amounts, application period, etc.
Recertification for vulnerable households (elderly, disabled, families with small children,
or veterans) will be done during the first month of the program year.
2.5
Check the variables you use to determine your benefit levels. (Check all that apply):
Income
Family (household) size
Home energy cost or need:
Fuel type
Climate/region
Individual bill
Dwelling type
Energy burden (% of income spent on home energy)
Energy need
Other (Describe)
See the LIHEAP Benefit Matrix Attachment. The benefit matrix has maximum
amounts. The amounts of the client’s bills can be paid up to the maximum amount.
We do not place a minimum on the benefit matrix because the amount of the bill is
paid.
GRANTEE Mississippi
FFY 24
Benefit Levels, 2605(b)(5) – Assurance 5, 2605(c)(1)(B)
2.6
Describe benefit levels:
$ 1.00 Minimum benefit
$ 1,500 Maximum benefit
Total benefit for year (can be divided between heating, cooling or crisis).
2.7
Do you provide in-kind (e.g., blankets, space heaters) and/or other forms of benefits?
Yes
No -- If yes, describe.
Blankets, coats, heating systems, furnaces and other heating, energy-related
materials/services may be provided depending on need.
GRANTEE Mississippi
FFY 24
Section 3: COOLING ASSISTANCE
Eligibility, 2605(c)(1)(A), 2605(b)(2) – Assurance 2
3.1
Designate the income eligibility threshold used for the cooling component:
FY 2023 state median income ____60_____% for all Household sizes
3.2
Do you have additional eligibility requirements for COOLING ASSISTANCE
Yes
No
3.3
Check the appropriate boxes below and describe the policies for each.
Yes
No
âš« Do you require an assets test?
âš« Do you have additional/differing eligibility policies for:
• Renters?
• Renters living in subsidized housing?
• Renters with utilities included in the rent?
âš« Do you give priority in eligibility to:
• Elderly?
• Disabled?
• Young children?
• Households with high energy burdens?
• Other?
Explanations of policies for each “yes’ checked above:
See Eligibility and Benefit Determination Attachment.
The applicant should provide either a copy of their lease; a notarized statement from the
landlord detailing the heating/cooling arrangement with the client; or contract with the
landlord that verifies the heating/cooling arrangement that the landlord has with the
GRANTEE Mississippi
FFY 24
household. Persons/households residing in public/subsidized housing dwelling unless their
rent/mortgage includes utilities and they are not being billed separately for energy cost.
3.4
Describe how you prioritize the provision of cooling assistance to vulnerable households,
e.g., benefit amounts, application period, etc.
Recertification for vulnerable households (elderly, disabled, families with small children,
or veterans) will be done during the first month of the program year.
Determination of Benefits, 2605(b)(5) – Assurance 5, 2605(c)(1)(B)
3.5
Check the variables you use to determine your benefit levels. (Check all that apply):
Income
Family (household) size
Home energy cost or need
Fuel type
Climate/region
Individual bill
Dwelling type
Energy burden (% of income spent on home energy)
Energy need
Other (describe)
See the LIHEAP Benefit Matrix Attachment. The benefit matrix has maximum
amounts. The amounts of the client’s bills can be paid up to the maximum amount.
We do not place a minimum on the benefit matrix because the amount of the bill is
paid.
Benefit Levels, 2605(b)(5) – Assurance 5, 2605(c)(1)(B
3.6
Describe benefit levels:
$ 1.00 Minimum benefit
$ * 1,500 Maximum benefit
Total benefit for year (can be divided between heating, cooling or crisis).
GRANTEE Mississippi
FFY 24
3.7
Do you provide in-kind (e.g. fans, air conditioners) and/or other forms of benefits?
Yes
No -- If yes, describe.
Fans, air conditioners, cooling systems and other cooling energy-related service may be
provided depending on need.
GRANTEE Mississippi
FFY 24
Section 4: CRISIS ASSISTANCE
Eligibility - 2604(c), 2605(c)(1)(A)
4.1
Designate the income eligibility threshold used for the crisis component:
FY 2023 state median income ____60_______% for all Household sizes
4.2
Provide your LIHEAP program’s definition for determining a crisis.
See Crisis & Emergency Services Attachment
4.3
What constitutes a life-threatening crisis?
See Crisis & Emergency Services Attachment. For declared natural disasters, the State
will use LIHEAP funds to provide emergency housing for eligible households for up to five
days to remove the household from the emergency situation. Households will be referred
to other programs such as CSBG and state/local resources to provide other emergency
needs to include housing/food/clothing if the home is inhabitable.
Crisis Requirements, 2604(c)
4.4
Within how many hours do you provide crisis assistance that will resolve the energy crisis
for eligible households? ____48______ Hours
4.5
Within how many hours do you provide crisis assistance that will resolve the energy crisis
for eligible households in life-threatening situations? _____18_____ Hours
Crisis Eligibility, 2605(c)(1)(A)
4.6
Do you have additional eligibility requirements for CRISIS ASSISTANCE?
Yes
No
4.7
Check the appropriate boxes below and describe the policies for each.
Yes
No
âš« Do you require an assets test?
âš« Do you give priority in eligibility to:
• Elderly?
• Disabled?
• Young children?
GRANTEE Mississippi
FFY 24
• Households with high energy burdens?
• Other?
âš« In order to receive crisis assistance:
• Must the household have received a
shut-off notice or have a near empty tank?
• Must the household have been shut off
or have an empty tank?
• Must the household have exhausted
their regular heating benefit?
• Must renters with heating costs included
in their rent have received an eviction
notice?
• Must heating/cooling be medically
necessary?
• Must the household have non-working
heating or cooling equipment?
• Other?
âš« Do you have additional/differing eligibility policies for:
• Renters?
• Renters living in subsidized housing?
• Renters with utilities included in the rent?
Explanations of policies for each “yes’ checked above:
See Eligibility and Benefit Determination Attachment.
The applicant should provide either a copy of their lease; a notarized statement from the
landlord detailing the heating/cooling arrangement with the client; or contract with the
landlord that verifies the heating/cooling arrangement that the landlord has with the
household. Persons/households residing in public/subsidized housing dwelling unless their
rent/mortgage includes utilities, and they are not being billed separately for energy cost.
GRANTEE Mississippi
FFY 24
Determination of Benefits
4.8
How do you handle crisis situations?
Separate component
Fast Track
Other
4.9
If you have a separate component, how do you determine crisis assistance benefits?
Amount to resolve crisis, up to a maximum of $1,500 depending on the Benefits
Matrix amount for the household. See the LIHEAP Benefit Matrix attachment.
Other
Crisis Requirements, 2604(c)
4.10
Do you accept applications for energy crisis assistance at sites that are geographically
accessible to all households in the area to be served?
Yes
No
4.11
Do you provide individuals who are physically disabled the means to:
â—Ľ Submit applications for crisis benefits without leaving their homes?
Yes
No If no, explain.
Case Workers may conduct home visits or they can authorize someone to make an
application on their behalf.
â—ĽTravel to the sites at which applications for crisis assistance are accepted?
Yes
No If no, explain.
If you answered "No" to both options in question 4.11, please explain alternative means of
intake to those who are homebound or physically disabled?
Case Workers may conduct home visits, or they can authorize someone to make an
application on their behalf.
GRANTEE Mississippi
FFY 24
Benefit Levels, 2605(c)(1)(B)
4.12
Indicate the maximum benefit for each type of crisis assistance offered.
Winter Crisis
$ maximum benefit
Summer Crisis
$ maximum benefit
Year-round Crisis
$ *1,500 maximum benefit
Total benefit for year (can be divided between heating, cooling, or crisis).
4.13
Do you provide in-kind (e.g. blankets, space heaters, fans) and/or other forms of benefits?
Yes
No
If yes, describe.
Blankets, coats, heating systems, furnaces and other heating, energy-related
materials/services may be provided during the winter. Fans, air conditioners, cooling
systems, and other cooling energy-related services may be provided during the summer.
4.14
Do you provide for equipment repair or replacement using crisis funds?
Yes
No
4.15
Check appropriate boxes below to indicate type(s) of assistance provided:
Winter
Crisis
Summer
Crisis
Year-
round
Crisis
Heating system repair
X
Heating system replacement
X
Cooling system repair
X
Cooling system replacement
X
Wood stove purchase
X
Pellet stove purchase
Solar panel(s)
Windmill(s)
Utility poles / Gas line hook-ups
X
Other (Specify): __Meter Bases, Propane Tank
Installation/removable____________
X
GRANTEE Mississippi
FFY 24
4.16
Do any of the utility vendors you work with enforce a winter moratorium on shut offs?
Yes
No
If you responded “Yes” to question 4.16, you must respond to question 4.17.
4.17
Describe the terms of the moratorium and any special dispensation received by LIHEAP
clients during or after the moratorium period.
If as of 8:00 a.m. on the day of a scheduled non-pay disconnect, an excessive heat warning
or a freeze warning has been issued by the National Weather Service for the county of the
scheduled disconnect, such disconnects are suspended.
Intervention for vulnerable households can be
done until the repair or replacement of units can be
completed. Emergency housing in cases of
extreme heat or cold, or federal/state declared
disaster can be provided up to five days until crisis
is solved. Meter bases on homes may be repaired
or replaced.
GRANTEE Mississippi
FFY 24
Section 5: WEATHERIZATION ASSISTANCE
Eligibility, 2605(c)(1)(A), 2605(b)(2) – Assurance 2
5.1
Designate the income eligibility threshold used for the weatherization component:
HHS poverty income level ________% for all Household sizes
5.2
Do you enter into an interagency agreement to have another government agency administer
a WEATHERIZATION component?
Yes
No
5.3
Name the agency. _________________________________________________
5.4
Is there a separate monitoring protocol for weatherization?
Yes
No
WEATHERIZATION - Types of Rules
5.5
Under what rules do you administer LIHEAP weatherization? (Check only one.)
Entirely under LIHEAP (not DOE) rules
Entirely under DOE WAP (not LIHEAP) rules
Mostly under LIHEAP rules with the following DOE WAP rule(s) where LIHEAP
and WAP rules differ: (Check all that apply.)
Income Threshold
Weatherization of entire multi-family housing structure is permitted if at least
66% of units (50% in 2- & 4-unit buildings) are eligible units or will become
eligible within 180 days.
Weatherization of shelters temporarily housing primarily low income persons
(excluding nursing homes, prisons, and similar institutional care facilities) is
permitted.
Other (describe)
Mostly under DOE WAP rules, with the following LIHEAP rule(s) where LIHEAP and
WAP rules differ: (Check all that apply.)
Income Threshold
Weatherization not subject to DOE WAP maximum statewide average cost per
dwelling unit.
GRANTEE Mississippi
FFY 24
Weatherization measures are not subject to DOE Savings to Investment Ratio
(SIR) standards.
Other (describe)
Eligibility, 2605(b)(5) – Assurance 5
Yes
No
5.6
Do you require an assets test?
5.7
Do you have additional/differing eligibility policies for:
•
Renters?
•
Renters living in subsidized housing?
5.8
Do you give priority in eligibility to:
•
Elderly?
•
Disabled?
•
Young children?
•
Households with high energy burdens?
•
Other?
If you selected "Yes" for any of the options in questions 5.6, 5.7, or 5.8, you must provide
further explanation of these policies in the text field below.
Benefit Levels
5.9
Do you have a maximum LIHEAP weatherization benefit/expenditure per household?
Yes
No
5.10
What is the maximum amount? $___________
Types of Assistance, 2605(c)(1), (B) & (D)
5.11
What LIHEAP weatherization measures do you provide? (Check all categories that apply.)
GRANTEE Mississippi
FFY 24
Weatherization needs
assessments/audits
Caulking and insulation
Install storm windows
Furnace/Heating system
modifications/repairs
Furnace replacement
Cooling system modifications/repairs
Cooling system replacement
Energy related roof repair
Major appliance repairs
Major appliance replacement
Install windows/sliding glass doors
Install doors (interior/exterior) (if
broken)
Install water heater
Water conservation measures
Compact florescent light bulbs
Other (describe)
GRANTEE Mississippi
FFY 24
Section 6: Outreach, 2605(b)(3) – Assurance 3, 2605(c)(3)(A)
6.1
Select all outreach activities that you conduct that are designed to assure that eligible
households are made aware of all LIHEAP assistance available:
Place posters/flyers in local and county social service offices, offices of aging, Social
Security offices, VA, etc.
Publish articles in local newspapers or broadcast media announcements.
Include inserts in energy vendor billings to inform individuals of the availability of all
types of LIHEAP assistance.
Mass mailing(s) to prior-year LIHEAP recipients.
Inform low income applicants of the availability of all types of LIHEAP assistance at
application intake for other low-income programs.
Execute interagency agreements with other low-income program offices to perform
outreach to target groups.
Other (specify):
GRANTEE Mississippi
FFY 24
Section 7: Coordination, 2605(b)(4) – Assurance 4
7.1
Describe how you will ensure that the LIHEAP program is coordinated with other
programs available to low-income households (TANF, SSI, WAP, etc.)
Joint application for multiple programs
Intake referrals to/from other programs
One-stop intake centers
Other – describe:
See Coordination of LIHEAP Activities Attachment
The State has one application for four programs – LIHEAP, CSBG, LIHWAP and Weatherization.
Therefore, an application may apply for all programs during the intake process. If the
weatherization agency is different from the LIHEAP agency, the LIHEAP agency refers to the
weatherization agency to complete the assessment for this program. Local agencies offer all
programs administered by that agency, especially to the vulnerable populations of elderly,
disabled, families with children, and veterans. Local agencies refer applicants to other local offices
such as SNAP and TANF if applicant is not currently receiving these services.
Also, the department has the Common Web Portal (CWP), households can apply for LIHEAP
when they apply for SNAP and Medicaid.
GRANTEE Mississippi
FFY 24
Section 8: Agency Designation, 2605(b)(6) – Assurance 6
8.1
How would you categorize the primary responsibility of your State agency?
Administration Agency
Commerce Agency
Community Services Agency
Energy/Environment Agency
Housing Agency
Welfare Agency
Other – describe:
Alternate Outreach and Intake, 2605(b)(15) – Assurance 15
If you selected “Welfare Agency” in question 8.1, you must complete questions 8.2, 8.3, and 8.4,
as applicable.
8.2
How do you provide alternate outreach and intake for HEATING ASSISTANCE?
The State Agency also administers the State Welfare Program; however, different divisions
administer the LIHEAP and Welfare Programs. The Division of Community Services
partners with the Division of Economic Assistance, Division of Child Support, and other
divisions within the agency to ensure that low-income elderly, disabled families have
access to all eligible services. All eighty-two counties across the state are serviced by
qualified Case Manager/Caseworkers that provide outreach and intake services. The
typical hours of operation for eligible entities are Monday-Friday from 7:30 am – 6:00
pm.
8.3
How do you provide alternate outreach and intake for COOLING ASSISTANCE?
The State Agency also administers the State Welfare Program; however, different divisions
administer the LIHEAP and Welfare Programs. The Division of Community Services
partners with the Division of Economic Assistance, Division of Child Support, and other
divisions within the agency to ensure that low-income elderly, disabled families have
access to all eligible services. All eighty-two counties across the state are serviced by
qualified Case Manager/Caseworkers that provide outreach and intake services. The
typical hours of operations for eligible entities are Monday – Friday from 7:30 am – 6:00
pm.
8.4
How do you provide alternate outreach and intake for CRISIS ASSISTANCE?
GRANTEE Mississippi
FFY 24
The State Agency also administers the State Welfare Program, however, different divisions
administer the LIHEAP and Welfare Programs. The Division of Community Services
partners with the Division of Economic Assistance, Division of Child Support and other
divisions within the agency to ensure that low-income elderly, disabled families have
access to all eligible services. All eighty-two counties across the state are serviced by
qualified Case Manager/Caseworkers that provide outreach and intake services. The
typical hours of operations for eligible entities are Monday – Friday from 7:30 am – 6:00
pm.
8.5.
LIHEAP Component Administration.
Heating
Cooling
Crisis
Weatherization
8.5a: Who determines client eligibility?
CAA
CAA
CAA
N/A
8.5b: Who processes benefit payments to
gas and electric vendors?
CAA
CAA
CAA
N/A
8.5c: Who processes benefit payments to
bulk fuel vendors?
CAA
CAA
CAA
N/A
8.5d: Who performs installation of
weatherization measures?
N/A
N/A
N/A
N/A
If any of your LIHEAP components are not centrally-administered by a state agency, you must
complete questions 8.6, 8.7, 8.87, and, if applicable, 8.9.
8.6
What is your process for selecting local administering agencies?
We have chosen agencies based on prior experience administering similar programs such
as CSBG. The State sends the Notice of Funding Availability (NOFA) to local agencies to
respond and submit a subgrant proposal for review. The subgrant is reviewed by the
Division of Community Services and Division of Procurement Services and AGs Office to
ensure all fiscal and programmatic requirements are met. The subgrant is sent to the
Executive Director’s office for signature after division reviews have been completed and
approved.
8.7
How many local administering agencies do you use?
8.8
Have you changed any local administering agencies from last year?
Yes
No
8.9
If so, why?
GRANTEE Mississippi
FFY 24
Agency was in noncompliance with grantee requirements for LIHEAP
Agency is under criminal investigation
Added agency
Agency closed
Other – describe:
GRANTEE Mississippi
FFY 24
Section 9: Energy Suppliers, 2605(b)(7) – Assurance 7
9.1
Do you make payments directly to home energy suppliers?
Heating
Yes
No
Cooling
Yes
No
Crisis
Yes
No
Are there exceptions?
Yes
No
If yes, describe.
9.2
How do you notify the client of the amount of assistance paid?
Agencies must provide written notification to clients regarding the status of their
application within 72 hours of approval for services. The notification letter must be
scanned into Virtual ROMA and a copy placed into client’s file. In the case of an
emergency, this notification should occur within 24 hours of application for services. The
person who approves the application in Virtual ROMA should generate the letter.
If a client’s application is denied, the agency must provide written explanation with the
reason for the denial. The Fair Hearing Process must be included in the letter sent to the
client. The person who denies the application in Virtual ROMA should generate the letter.
9.3
How do you assure that the home energy supplier will charge the eligible household, in the
normal billing process, the difference between the actual cost of the home energy and the
amount of the payment?
Vendor Agreements the CAA has with the energy supplier provides this assurance.
9.4
How do you assure that no household receiving assistance under this title will be treated
adversely because of their receipt of LIHEAP assistance?
Vendor Agreements the CAA has with the energy supplier provides this assurance.
9.5
Do you make payments contingent on unregulated vendors taking appropriate measures to
alleviate the energy burdens of eligible households?
Yes
No. If so, describe the measures unregulated vendors may take.
GRANTEE Mississippi
FFY 24
Section 10: Program, Fiscal Monitoring, and Audit, 2605(b)(10) – Assurance 10
10.1. How do you ensure good fiscal accounting and tracking of LIHEAP funds?
See Fiscal Accounting and Tracking Requirements attachment.
Audit Process
10.2. Is your LIHEAP program audited annually under the Single Audit Act and OMB Circular
A-133?
Yes
No
10.3. Describe any audit findings rising to the level of material weakness or reportable condition
cited in the A-133 audits, Grantee monitoring assessments, inspector general reviews, or
other government agency reviews of the LIHEAP agency from the most recently audited
federal fiscal year.
Finding Type
Brief Summary
Resolved?
Action Taken
Financial
Strengthen controls to ensure
proper review processes for
financial reporting.
Yes
Procedure/Policy
changes
Monitoring
Strengthen controls over On-
Site Monitoring for the Low-
Income Home Energy
Assistance Program
(LIHEAP).
In
Progress
Procedure/Policy
changes
Monitoring
Strengthen controls over
Subrecipient Monitoring to
Ensure Compliance with
Uniform Guidance Auditing
Requirements.
In
Progress
Procedure/Policy
changes
10.4. Audits of Local Administering Agencies
o What types of annual audit requirements do you have in place for local administering
agencies/district offices?
Local agencies/district offices are required to have an annual audit in compliance
with the Single Audit Act and OMB Circular A-133.
GRANTEE Mississippi
FFY 24
Local agencies/district offices are required to have an annual audit (other than A-
133).
Local agencies/district offices’ A-133 or other independent audits are reviewed by
Grantee as part of compliance process.
Grantee conducts fiscal and program monitoring of local agencies/district offices.
Compliance Monitoring
10.5. Describe the Grantee’s strategies for monitoring compliance with the Grantee’s and
Federal LIHEAP policies and procedures by:
Grantee employees:
Internal program review
Departmental oversight
Secondary review of invoices and payments
Other program review mechanisms are in place. Describe:
Local Administering Agencies/District Offices:
On-site evaluation
Annual program review
Monitoring through Central Database
Desk reviews
Client File Testing/Sampling
Other program review mechanisms are in place. Describe:
10.6. Explain, or attach a copy of, your local agency monitoring schedule and protocol.
See MDHS Division of Monitoring and DCS (T&TA) attachment
10.7. Describe how you select local agencies for monitoring reviews?
Site Visits: All are monitored.
GRANTEE Mississippi
FFY 24
Desk Reviews: Monthly financial and program reports are reviewed.
10.8. How often is each local agency monitored?
Every three (3) years
10.9. What is the combined error rate for eligibility determinations? (OPTIONAL)
10.10. What is the combined error rate for benefit determinations? (OPTIONAL)
10.11. How many local agencies are currently on corrective action plans for eligibility and/or
benefit determination issues?
None
10.12. How many local agencies are currently on corrective action plans for financial accounting
or administrative issues?
None
GRANTEE Mississippi
FFY 24
Section 11: Timely and Meaningful Public Participation, 2605(b)(12) – Assurance 12,
2605(c)(2)
11.1
How did you obtain input from the public in the development of your LIHEAP plan?
Check all that apply:
Tribal Council meeting(s)
Public Hearing(s)
Draft Plan posted to website and available for comment
Hard copy of plan is available for public view and comment
Comments from applicants are recorded
Request for comments on draft Plan is advertised (in the Legal Notice)
Stakeholder consultation meeting(s)
Comments are solicited during outreach activities
Other, describe: Draft plan posted by the Secretary of State’s Office for public view
and comments. Draft plan is reviewed by DHS Compliance Division.
11.2
What changes did you make to your LIHEAP plan as a result of this participation?
None
Public Hearings, 2605(a)(2)
11.3 List the date(s) and location(s) that you held public hearing(s) on the proposed use and
distribution of your LIHEAP funds?
Date
Event Description
June 27, 2023
Mississippi Department of Human Services, 200 South Lamar St.,
Jackson, MS 39201, “Zoom Meeting”
11.4
How many parties commented on your plan at the hearing(s)?
None
11.5
Summarize the comments you received at the hearing(s).
None
GRANTEE Mississippi
FFY 24
11.6 What changes did you make to your LIHEAP plan as a result of the public hearing(s)?
None
GRANTEE Mississippi
FFY 24
Section 12: Fair Hearings, 2605(b)(13) – Assurance 13
12.1
How many fair hearings did the grantee have in the prior Federal fiscal year?
None
12.2
How many of those fair hearings resulted in the initial decision being reversed?
None
12.3 Describe any policy and/or procedural changes made in the last Federal fiscal year as a
result of fair hearings?
None
12.4
Describe your fair hearing procedures for households whose applications are denied.
See Fair Hearing Policy Attachment
12.5
When and how are applicants informed of these rights?
Clients are informed of the Fair Hearing Process during intake process at the CAA. Upon
intake and denial of services, a copy of the Fair Hearing Process is given or will be mailed
with the denial letter to the applicant. The process for fair hearings is clearly posted in
county offices. The Fair Hearing process is posted on Virtual ROMA so applicants have
access during CWP process.
12.6 Describe your fair hearing procedures for households whose applications are not acted on
in a timely manner.
See Fair Hearing Policy Attachment
12.7
When and how are applicants informed of these rights?
Clients are given a copy of the Fair Hearing Process during intake process at the CAA.
Upon denial of services, a copy of the Fair Hearing Process is given or will be mailed
with the denial letter to the applicant. The process for fair hearings is clearly posted in
county offices. The Fair Hearing process is posted on Virtual ROMA so applicants have
access during CWP process.
GRANTEE Mississippi
FFY 24
Section 13: Reduction of home energy needs, 2605(b)(16) – Assurance 16
13.1 Describe how you use LIHEAP funds to provide services that encourage and enable
households to reduce their home energy needs and thereby the need for energy assistance?
N/A
13.2 How do you ensure that you don't use more than 5% of your LIHEAP funds for these
activities?
N/A
13.3 Describe the impact of such activities on the number of households served in the previous
Federal fiscal year.
N/A
13.4 Describe the level of direct benefits provided to those households in the previous Federal
fiscal year.
N/A
13.5 How many households applied for these services?
13.6 How many households received these services?
GRANTEE Mississippi
FFY 24
Section 14: Leveraging Incentive Program, 2607A
14.1
Do you plan to submit an application for the leveraging incentive program?
Yes
No
14.2 Describe instructions to the third parties and/or local agencies for submitting LIHEAP
leveraging resource information and retaining records.
The State shall participate in the LIHEAP Leveraging Program. The State and local
subgrantees will solicit non-federal dollars in order to qualify to compete for leveraging
incentive funds. Several organizations, individuals, etc. will be contacted to make cash
and in-kind contributions, such as discounts, arrearage forgiveness, fuel funds, credit,
volunteer, WX materials, waivers: disconnections, deposits, and reconnect fees, etc. *
Leveraged resources/benefits that are counted under criterion (iii) in 45 CFR 96.87(d)(2)
must be identified and described in the grantees LIHEAP plan and distributed as
indicated in the plan. In addition, leveraging resources/benefits that are counted under
criterion (ii) must be carried out under one or more components of the grantee's regular
LIHEAP program.
14.3 For each type of resource and/or benefit to be leveraged in the upcoming year that will
meet the requirements of 45 C.F.R. § 96.87(d)(2)(iii), describe the following:
Resource What is the type of
resource or benefit?
What is the source(s) of
the resource?
How will the resource be
integrated and coordinated with
the LIHEAP program?
Cash and in-kind
contributions, such as
discounts, arrearage
forgiveness, fuel
funds, credit,
volunteer, WX
materials, waivers:
disconnections,
deposits, and
reconnect fees, etc.
Several organizations,
individuals
The State coordinates leveraging
with the LIHEAP program to
provide consumer education with
our clients to encourage them to
conserve energy and the
disadvantages of getting services
interrupted. Leveraging resources
also provide additional services
to more clients in LIHEAP.
Coordination also compliments
our budget program in LIHEAP
to allow clients to better manage
resources.
Private sources
Entergy Helping Hands
Partnerships donated funds to
pay energy related bills
GRANTEE Mississippi
FFY 24
*Leveraged resources/benefits that are counted under criterion (iii) in 45 CFR 96.87(d)(2) must
be identified and described in the grantees LIHEAP plan and distributed as indicated in the plan.
In addition, leveraging resources/benefits that are counted under criterion (ii) must be carried out
under one or more components of the grantee’s regular LIHEAP program
GRANTEE Mississippi
FFY 24
Section 15: Training
15.1. Describe the training you provide for each of the following groups:
a. Grantee Staff:
Formal training on grantee policies and procedures
How often?
Annually
Biannually
As needed
Other – Describe:
Employees are provided with policy manual
Other – Describe:
b. Local Agencies:
Formal training conference
How often?
Annually
Biannually
As needed
Other – Describe:
On-site training
How often?
Annually
Biannually
As needed
GRANTEE Mississippi
FFY 24
Other – Describe:
Employees are provided with policy manual
Other – Describe:
c. Vendors
Formal training conference
How often?
Annually
Biannually
As needed
Other – Describe:
Policies communicated through vendor agreements
Policies are outlined in a vendor manual
Other – Describe:
15.2. Does your training program address fraud reporting and prevention?
Yes
No
GRANTEE Mississippi
FFY 24
Section 16: Performance Goals and Measures, 2605(b)
16.1
Describe your progress toward meeting the data collection and reporting requirements of
the four required LIHEAP performance measures. Include timeframes and plans for
meeting these requirements and what you believe will be accomplished in the coming
federal fiscal year.
The State of MS has updated its centralized client tracking system (Virtual ROMA
2- VR 2) to capture, analyze and submit information regarding energy burden,
targeting, restoration/prevention of loss of home energy service. The
State successfully submits the LIHEAP Performance Measures Report. We continue
to work with APPRISE to analyze report and use data to enhance the LIHEAP
program.
There were several enhancements made specifically for LIHEAP:
• LIHEAP Monthly, Quarterly & Annual Report generated and able to be run on the
fly by state users.
• Supplemental Payment Processing
• Auto allocation of LIHEAP Benefits based on Grant Specifications
• Executive Report for Households Served
• Check Reissue Feature Rolling Out August 2023 to streamline process
• System Alerts or Supplemental Payment Recipients
• VR2 Notifications
2024 Planned System Enhancements
• NEADA Report Generation
• Energy Burden Indicator on HH Profile
• Aging Report
• CWP Dashboard integration with VR to notify clients about benefits/application
status, with full access accounts;
o Offer ability to upload documents if missing during intake; ability to request
appointments/ appointment letters.
• Grant Management component to help monitor & alert for budget attainment –
spending tracking.
• Performance Report for Division on stabilized homes during the month to include
vulnerable populations (may be Sept 2023)
GRANTEE Mississippi
FFY 24
Section 17: Program Integrity, 2605(b)(10)
17.1 Fraud Reporting Mechanisms
a. Describe all mechanisms available to the public for reporting cases of suspected waste,
fraud, and abuse.
Online Fraud Reporting
Dedicated Fraud Reporting Hotline
Report directly to local agency/district office or Grantee office
Report to State Inspector General or Attorney General
Forms and procedures in place for local agencies/district offices and vendors to
report fraud, waste, and abuse.
Other – describe: Report to the MDHS – Office of Inspector General
b. Describe strategies in place for advertising the above-referenced resources.
Printed outreach materials
Addressed on LIHEAP application
Website - MDHS website
Other – describe:
GRANTEE Mississippi
FFY 24
17.2 Identification Documentation Requirements
a. Indicate which of the following forms of identification are required or requested to be
collected from LIHEAP applicants or their household members.
REQUIRED Type of
Identification Collected
Collected from Whom?
Applicant Only
All Adults in
HH
All Household
Members
Social Security Card is
photocopied and retained
Required
Required
Required
Requested
Requested
Requested
Social Security Number
(without actual card)
Required
Required
Required
Requested
Requested
Requested
Government-issued
identification card (i.e.:
driver’s license, state ID,
Tribal ID, passport, etc.)
Required
Required
Required
Requested
Requested
Requested
Other:
Required
Required
Required
b. Describe any exceptions to the above policies.
Exceptions for newborn children.
17.3 Identification Verification
Describe what methods are used to verify the authenticity of identification documents
provided by clients or household members. Select all that apply.
Verify SSNs with Social Security Administration
Match SSNs with death records from Social Security Administration or state agency
Match SSNs with state eligibility/management system (e.g., SNAP, TANF)
Match with state Department of Labor system
Match with state and/or federal corrections system
Match with state child support system
Verification using private software (e.g., The Work Number)
In-person certification by staff
GRANTEE Mississippi
FFY 24
Match SSN/Tribal ID number with tribal database
Other – describe:
In Person Verification
17.4 Citizenship/Legal Residency Verification
What are your procedures for ensuring that household members are U.S. citizens or aliens
who are qualified to receive LIHEAP benefits? Select all that apply.
Clients sign an attestation of citizenship or legal residency
Clients’ submission of Social Security cards is accepted as proof of legal residency
Noncitizens must provide documentation of immigration status
Citizens must provide a copy of their birth certificate, naturalization papers, or passport
Noncitizens are verified through the SAVE system
Tribal members are verified through Tribal database/Tribal ID card
Other – describe:
17.5 Income Verification
What methods does your agency utilize to verify household income? Select all that apply.
Require documentation of income for all adult household members
Pay stubs
Social Security award letters
Bank statements
Tax statements
Zero-income statements
Unemployment Insurance letters
Other – describe:
GRANTEE Mississippi
FFY 24
Computer data matches:
Income information matched against state computer system (e.g., SNAP,
TANF)
Proof of unemployment benefits verified with state Department of Labor
Social Security income verified with SSA
Utilize state directory of new hires
Other – describe:
17.6
Protection of Privacy and Confidentiality
Describe the financial and operating controls in place to protect client information against
improper use or disclosure. Select all that apply.
Policy in place prohibiting release of information without written consent
Grantee LIHEAP database includes privacy/confidentiality safeguards
Employee training on confidentiality for:
Grantee employees
Local agencies/district offices
Employees must sign confidentiality agreement
Grantee employees
Local agencies/district offices
Physical files are stored in a secure location
Other – describe:
17.7 Verifying the Authenticity of Energy Vendors
What policies are in place for verifying vendor authenticity? Select all that apply.
All vendors must register with the State
All vendors must supply a valid SSN or TIN/W-9 form
GRANTEE Mississippi
FFY 24
Vendors are verified through energy bills provided by the household
Grantee and/or local agencies/district offices perform physical monitoring of vendors
Other – describe, and note any exceptions to policies above:
17.8
Benefits Policy – Gas and Electric Utilities
What policies are in place to protect against fraud when making benefit payments to gas
and electric utilities on behalf of clients? Select all that apply.
Applicants required to submit proof of physical residency
Applicants must submit current utility bill
Data exchange with utilities that verifies:
Account ownership
Consumption
Balances
Payment history
Account is properly credited with benefit
Other – describe:
Centralized computer system/database tracks payments to all utilities
Centralized computer system automatically generates benefit level
Separation of duties between intake and payment approval
Payments coordinated among other heating assistance programs to avoid duplication
of payments
Payments to utilities and invoices from utilities are reviewed for accuracy
Computer databases are periodically reviewed to verify accuracy and timeliness of
payments made to utilities
Direct payment to households are made in limited cases only
GRANTEE Mississippi
FFY 24
Procedures are in place to require prompt refunds from utilities in cases of account
closure
Vendor agreements specify requirements selected above, and provide enforcement
mechanism
Other – describe:
17.9
Benefits Policy — Bulk Fuel Vendors
What procedures are in place for averting fraud and improper payments when dealing with
bulk fuel suppliers of heating oil, propane, wood, and other bulk fuel vendors? Select all
that apply.
Vendors are checked against an approved vendors list
Centralized computer system/database is used to track payments to all vendors
Clients are relied on for reports of non-delivery or partial delivery
Two-party checks are issued naming client and vendor
Direct payment to households are made in limited cases only
Conduct monitoring of bulk fuel vendors
Bulk fuel vendors are required to submit reports to the Grantee
Vendor agreements specify requirements selected above, and provide enforcement
mechanism
Other – describe:
17.10 Investigations and Prosecutions
Describe the Grantee’s procedures for investigating and prosecuting reports of fraud, and
any sanctions placed on clients/staff/vendors found to have committed fraud. Select all that
apply.
Refer to state Inspector General
Refer to local prosecutor or state Attorney General
Refer to US DHHS Inspector General (including referral to OIG hotline)
GRANTEE Mississippi
FFY 24
Local agencies/district offices or Grantee conduct investigation of fraud complaints
from public
Grantee attempts collection of improper payments. If so, describe the recoupment
process.
See Waste, Fraud & Abuse Policy
Clients found to have committed fraud are banned from LIHEAP assistance. For how
long is a household banned? 1 year (1st offense). Indefinitely (2nd offense).
Contracts with local agencies require that employees found to have committed fraud
are reprimanded and/or terminated
Vendors found to have committed fraud may no longer participate in LIHEAP
Other – describe:
GRANTEE Mississippi
FFY 24
Attachments
GRANTEE Mississippi
FFY 24
ATTACHMENT-TENTATIVE FFY 2024 ALLOCATIONS
(These levels are dependent on the Federal LIHEAP award at the FFY 2023 level.
Adjustments will be made once the final FFY 2024 awards are known.)
Eligible Entities
Allocation
AJFC CAA
$1,667,529
Bolivar Co CAA
$682,171
Central Mississippi
$2,079,864
Coahoma Opportunities
$485,099
Community Action of South MS
$2,410,337
Hinds County HRA
$1,352,215
LIFT
$2,625,600
Madison Co. CSA
$615,470
Mid-State Opportunities
$1,928,270
Multi County CSA
$2,561,931
Northeast MS
$1,531,095
PRVO
$4,080,898
Prairie Opportunity
$2,380,019
South Central CAA
$2,331,508
Southwest MS
$1,021,741
Sunflower-Humphreys Co
$654,884
WWISCAA
$1,910,079
Total
$30,318,710
GRANTEE Mississippi
FFY 24
ATTACHMENT- POVERTY GUIDELINES
CSBG and LIHEAP applicants must first meet income guidelines to be eligible for assistance.
Also, non-elderly/non-disabled clients must be placed in case management.
A. CSBG: The income of all household members may not exceed 125% of the federal poverty
guidelines as established by Department of Health and Human Services (HHS).
B. LIHEAP: The income of all household members may not exceed 60% of the state median
income for Mississippi.
GRANTEE Mississippi
FFY 24
ATTACHMENT-2024 LIHEAP BENEIFIT MATRIX
LIHEAP Benefit Matrix (Fuel Types)
The LIHEAP Act stipulates that households with high energy costs and needs receive the
greatest benefit. LIHEAP Benefits are now capped based on income levels and size of
household income. LIHEAP benefits are capped at $1500 per program year.
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
ATTACHMENT-ELIGIBILITY
Statutory Reference 2605 (b) (5)
2605 (b) (2)
2605 (b) (8) (A)
2605(b) (10)
The State assures through Virtual ROMA that it will provide, in a timely manner, the highest level
of assistance to those households (with the highest home energy needs which takes into account
both the energy burden and the unique situation of the vulnerable population) which have the
lowest incomes and the highest home energy cost in relation to income, taking into account family
size, except that the State may not differentiate in implementing this section between the
households described in the above referenced clauses.
The State further assures that it will not differentiate in the treatment of households eligible for
services because of their income and as the recipients of TANF, Food Stamps, SSI or certain
means-tested veterans program certified as “categorically eligible”. This applies to all LIHEAP
components (cooling, heating, crisis and weatherization).
The specific measures to ensure there is no difference in eligibility determination and benefit
amounts is not to use categorical eligibility in all components. All applicant households must
complete the established application process, case management process and eligibility
determination.
The utilization of Virtual ROMA has resulted in additional fiscal control tracking capabilities for
LIHEAP funds by:
• All LIHEAP funds expended must originate via Virtual ROMA.
• LIHEAP payments only occur based on client services that are in “approved” status in
Virtual ROMA.
• Greater visibility by State to view, monitor and track fiscal process and payment on a state-
wide basis across agencies.
• Programmatic staff must work closely with fiscal staff to determine timeframe for payment
so that program reports are generated for the specified timeframe and given to fiscal.
• Fiscal compares, reviews and authorizes payment report before any payment. Any
discrepancies identified between Program Reports and the electronic payment files are
reconciled by Fiscal and Program before payment occurs.
• Virtual ROMA prohibits approvals from unauthorized program users and restricts any
Fiscal User from the ability to approve client services.
• Energy vendors who are registered users of Virtual ROMA are able to review their
clients’ approved amounts and compare to ensure accuracy of amounts and clients’
accounts.
GRANTEE Mississippi
FFY 24
ATTACHMENT- ELIGIBILITY AND BENEFIT DETERMINIATION
Statutory Reference 2605 (B) (2)
Each applicant household requesting for LIHEAP assistance must complete application process
for eligibility determination.
Income eligibility is set at or below 60% of the State Median Income guidelines that are in effect
at the time of submission of the application. An application is taken on the applicant household
by the local subgrantee agencies. All applications must be taken in the Virtual ROMA system.
Assistance from another program may also be provided to eligible households, especially those
households enrolled in and complying with an established service plan.
A household cannot receive more than $1,500 in benefits for the program year unless the State
issues supplemental payments. Total benefit for year (can be divided between heating, cooling or
crisis). This amount may be adjusted from year to year based on the state’s allocation. An
exception will be given to clients in need of a heating/cooling unit. The cost of the unit is not
included in the $1,500 maximum benefit amount.
Priority is given to the elderly and disabled. Live-in attendants’ income can be excluded if it is
determined that (1) the live-in is essential to the care and well-being of the person; and (2) would
not be living in the unit except to provide the necessary supportive services.
GRANTEE Mississippi
FFY 24
ATTACHMENT-COORDINATION OF LIHEAP ACTIVITIES
Statutory reference 2605 (b) (4)
The State agrees to coordinate its activities under this title with similar and related programs
administered by the Federal Government and the State, particularly low-income energy-related
programs under Subtitle B of Title VI (relating to Community Services Block Grant Program),
under the Supplemental Security Income Program under Part A of Title IV of the Social Security
Act, under Title XX of the Social Security Act, under the Low-Income Weatherization Assistance
Program, under Title IV of the Energy Conservation and Production Act, or under any other
provision of law which carries out programs which were administered under the Economic
Opportunity Act of 1964, before the date of the enactment of this Act.
The Division of Community Services (DCS) of the Mississippi Department of Human Services
administers LIHEAP, the Community Services Block Grant (CSBG), Low-Income Household
Water Assistance Program (LIHWAP) and the Low-Income Weatherization Assistance Program
(WAP). By operating these programs under one division, it provides high potential for enhancing
coordination. Also, it minimizes duplication of services between LIHEAP and other related
programs under the Social Security Act, the Energy Conservation and Production Act and other
related programs which are administered under the Economic Opportunity Act of 1964. A referral
mechanism is in place (through the case management approach) to refer to, and receive referrals
from other social service providers and energy vendors. LIHEAP clients identified as high energy
users due to the poor condition of their homes are referred to the Weatherization Assistance Program,
and priority is given to elderly and disabled individuals.
Other forms of coordination involves soliciting local funds as leveraging from organizations,
individuals, philanthropy agencies and energy vendors. The leveraging funds generated are used
to maintain the level of service or to assist additional eligible clients. Subgrantees are encouraged
to participate in leveraging local funds to supplement LIHEAP.
DCS will use one automated intake application for all the programs (LIHEAP, LIHWAP, WAP, and
CSBG), called the Virtual ROMA Tracking System. In addition, each applicant household's case
folder (personal data information) is placed in one file known as a single filing system. The one intake
application process and single filing system are viable means of coordinating efforts. It has the
potential of cost savings. Eligible LIHEAP clients are also approved for LIHWAP at the time of intake
since both programs have the same eligibility requirements.
MDHS elects to approach recipients of the LIHEAP program in a manner with the goal of assisting
those in need of immediate assistance and to assist with the long-term success of the whole family
through the use of referrals and assessments.
GRANTEE Mississippi
FFY 24
ATTACHMENT- CRISIS ASSISTANCE
Statutory reference 2604 (c), 2605 (c) (1) (A)
Mississippi offers a year-round crisis assistance component of LIHEAP, entitled the Energy
Crisis Intervention Program (ECIP), which provides assistance to low-income households who
have encountered a crisis situation within the last 30 days.
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
ATTACHMENT-PROGRAM, FISCAL MONITORING AND AUDIT
Statutory reference 2605 (b)(10)
Fiscal, Accounting and Tracking Requirements
The State requires Subgrantees requesting LIHEAP funds to submit Monthly Cost Worksheets in
Smartsheet. These Cost Worksheets show expenditures such as Program Assistance (regular),
ECIP, Assurance 16 (if budgeted) and Administration. Subgrantees are required to submit Claim
Support Forms (to request funds) based on Current Needs. Federal funds made available to the
State under this title will disburse administrative and programmatic funds to Subgrantees in
accordance with the LIHEAP Statute, and the overall contractual allocation for each subgrantee
regulates the maximum allowable expenditures. The expenditures and draw downs are processed
in the MDHS-Division of Procurement Services. The SF-425 Federal Fiscal Reports (FFR) are
generated in the MDHS – Division of Budgets & Accounting as well as the monthly reports for
DCS verification and tracking. Documentation from Virtual ROMA will be required to support
costs reflected on Cost Worksheets and Claims Support Forms as a means to adhere to mandates
by Division of Monitoring to monitor costs reported. Procedural manuals are in place which
covers a range of fiscal and accounting rules and regulations with which Subgrantees must comply.
Also, to further account for LIHEAP federal funds, 16 of 17 DCS Subgrantees use the same
accounting software, GMS, which allows tracking through Virtual ROMA. It allows easy access
in training new personnel, as well as existing personnel in the effective use of the GMS software
and DCS requirements.
Subgrantees are required to have and submit an annual audit performed annually by an independent
Certified Public Accountant. Also, the State complies with the Single Audit Act requirement.
The State continuously provides training and technical assistance to the subgrantees on program
and fiscal management to enhance program compliance and quality service delivery to eligible
households, and special training for new staff to ensure program compliance.
Subgrants will be monitored no less frequently than every three (3) years by the Division of
Monitoring. Periodic reviews to the subgrantee, both announced and unannounced will be
conducted by the Division of Community Services.
The Director of Monitoring reviews and approves audit findings and received from the Monitoring
Supervisor and provides the draft report for review to the Division of Community Services prior
to submitting to the subgrantee. Audit findings are addressed on the monitoring report.
GRANTEE Mississippi
FFY 24
SINGLE AUDIT MANAGEMENT REPORT AND FINDINGS REPORT
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
ATTACHMENT – LETTER OF AUTHORIZATION
GRANTEE Mississippi
FFY 24
GRANTEE Mississippi
FFY 24
ATTACHMENT – COMPLIANCE MONITORING
Division of Monitoring
Policy
The Division of Monitoring is tasked with ensuring that all subgrants of the Mississippi
Department of Human Services (MDHS) are administered in compliance with laws and regulations
applicable to Federal financial assistance programs, agency policies and in accordance with the
terms of the subgrant agreement and this subgrant manual in its entirety. Monitoring is a review
process used in determining a subgrantee’s compliance with the requirements of MDHS and/or
Federal programs, adhering to applicable laws and regulations, and measuring progress toward
stated results and outcomes. The Division of Monitoring along with the Programmatic Funding
Divisions are responsible for oversight of the development of appropriate monitoring instruments
specifically designed to ensure compliance with program requirements, cost principles, and federal
regulations.
MDHS monitoring reviews are performed in accordance with 2 C.F.R. §200, Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards and
have the following objectives:
1. Ensure accountability and compliance with applicable Federal and State laws applicable to
Federal financial assistance programs;
2. Ensure funds awarded to subgrantees are used for authorized purposes;
3. Ensure compliance with the terms of the subgrant agreement;
4. Identify technical assistance and training needs;
5. Ensure follow-up on issues and implementation of corrective actions;
6. Provide guidance to subgrantees in establishing and maintaining sound business
accounting procedures; and
7. Safeguard federal funds against fraud, waste, and abuse.
In general, the Subgrant monitoring procedures will consist of the following:
1. Notification of a monitoring review via a schedule letter;
2. Entrance Conference;
3. Examination of fiscal and programmatic requirements;
4. Exit Conference;
5. Initial Findings Letter;
6. Corrective Action Response and/or follow up;
7. Final Decision Letter; and
8. Administrative Hearings as required.
Monitoring of fiscal and programmatic requirements includes but is not limited to:
1. Reviewing expenditures to ensure funds are expended in line with the approved budget
narrative;
2. Reviewing claims submitted by the Subgrantee;
3. Reviewing documentation supporting expenses reported under MDHS subgrants;
GRANTEE Mississippi
FFY 24
4. Reviewing the subgrantee’s single audit and/or program-specific audit results and
evaluating audit findings and the subgrantee’s corrective action plan; and
5. Performing desk and/or on-site reviews of the fiscal and programmatic records and
observing subgrantee operations.
Monitoring Reviews for Program and Fiscal Compliance
The Division of Monitoring will conduct on-site and/or desk reviews of MDHS subgrants for
programmatic and fiscal compliance. The reviews may be performed on any subgrant at any time
and may be repeated as often as deemed necessary by MDHS. Subgrantees will receive a Schedule
Letter as notification of the impending monitoring review fourteen (14) calendar days prior to the
monitoring review. The Schedule Letter requests information and documentation from the
Subgrantee required to complete the monitoring review. MDHS reserves the right to conduct
unannounced reviews at its discretion.
Each review will conclude with an exit conference in which the monitor(s) will discuss with the
subgrantee signatory official (or designee) and other appropriate staff the preliminary results of
the review and whether any documentation remains outstanding.
The Division of Monitoring will issue an Initial Findings Letter within thirty (30) calendar days
after the exit conference. The monitoring report will provide a description of each finding of
noncompliance, identified questioned costs, and any required corrective action(s) to be taken by
the subgrantee. If the 30th calendar day falls on the weekend, the report will be issued the following
Monday. If due date falls on a State holiday, the report will be issued the following business day.
Corrective Action Procedures
The Initial Findings Letter is provided to the subgrantee via electronic mail correspondence. The
Division of Monitoring uses the current contact information included in the subgrant agreement.
It is the responsibility of the subgrantee to notify the Division of Monitoring if the correspondence
should be submitted to a different individual within the subgrantee organization. Copies of all
correspondence submitted to the subgrantee are also provided to the applicable MDHS
Programmatic Funding Division.
The subgrantee is required to provide a written response to the Division of Monitoring within thirty
(30) calendar days of receipt of the Initial Findings Letter, unless otherwise indicated. Any
extensions to provide documentation must be requested in writing and submitted before the final
due date. The corrective action plan must be specific and include:
1. A statement of whether the subgrantee agrees with the finding or not.
2. A detailed plan of how the subgrantee will correct each individual finding to prevent this
or similar finding in the future or justification for the subgrantee’s disagreement with the
finding(s).
3. Any subgrantee documents, forms, policy changes, reports, accounting tools, time sheets,
data collection forms, etc. that ensure the subgrantee has corrected the finding(s)
GRANTEE Mississippi
FFY 24
4. If the subgrantee disagrees with a finding(s) identified in the report, detailed documentation
must also be submitted to refute the questioned finding(s) and/or costs.
5. If the subgrantee agrees with the findings, the subgrantee must repay funds identified as
questioned costs to MDHS.
6. The corrective action plan must be signed by the Authorized Official or designee. (The
designee is the person granted permission to sign the Authorized Official’s signature.)
The Division of Monitoring will issue a Final Decision Letter based on the corrective action
response received from the subgrantee. If findings and/or questioned costs remain unresolved in
the Final Decision Letter, and the subgrantee disagrees with the final findings, the subgrantee can
appeal the findings. The subgrantee must request a Subgrant Agency Appeal within thirty (30)
calendar days from the date of receipt of the Final Decision Letter. Please refer to Title 18 of the
Administrative Code, Part 23, Chapter 7, Subgrant Administrative Agency Appeals for more
information.
Single Audit Requirements
Subgrantees must have a single-audit conducted, in accordance with 2 C.F.R. §200.514, by an
independent auditor if the Subgrantee expends $750,000 or more during the non-Federal entity's
fiscal year in Federal awards. Total federal grant awards not only include those received from the
MDHS, but also those received from any other source.
As part of its subrecipient monitoring functions, the Division of Monitoring reviews the single
audit reports for federal grant subrecipients that receive federal grants from MDHS. This
monitoring is done to ensure that federal grants are used for authorized purposes, in compliance
with federal statutes, regulations, and the terms and conditions of federal awards, as required by 2
C.F.R. §200.331. The subgrantee must submit the audit report to MDHS by the earlier of thirty
(30) calendar days after receipt of the auditor’s reports or nine (9) months from the end of the audit
period.
In compliance with 2 C.F.R. §200.512, Report Submission, subgrantees must electronically submit
a data collection form and the reporting package directly to the Federal Audit Clearinghouse
designated by OMB.
A subgrantee that expends Federal financial assistance during the subgrant’s fiscal year of:
1. Less than $750,000.00 shall be exempt from Federal audit requirements unless the
subgrantee meets a requirement in 2 C.F.R. §200.503. However, the subgrantee must make
records available for review by the appropriate officials and cannot constrain in any manner
such as a Federal or State agency, from carrying out or arranging audits; 2.
2. $750,000.00 or more under only one (1) Federal program and the Federal program’s
statutes, regulations or the terms and conditions of the Federal award do not require a
financial statement audit of the subgrant, may elect to have a program-specific audit in
accordance with 2 C.F.R. §200.507; or
3. $750,000.00 or more under more than one (1) Federal program shall have an organization
wide audit performed in accordance with 2 C.F.R. §200.501(c).
GRANTEE Mississippi
FFY 24
Program-Specific Audit
If the subgrantee meets the applicable standard for a program-specific audit, it must follow
Generally Accepted Government Auditing Standards (GAGAS) and the program specific audit
guide. A listing of current program-specific audit guides can be found in the compliance
supplement provided on the Office of Management and Budget website. If a current program
specific audit guide is not available, the subgrantee and auditor must have basically the same
responsibilities for the Federal program as they would have for an audit of a major program in a
single audit.
Limited Scope of Audits of Specific Compliance Areas
MDHS may engage an independent Certified Public Accountant to perform a Limited Scope Audit
of specified MDHS subgrants. The need for this type of review shall be determined on an
individual basis and shall be documented by MDHS. The results of this review shall be
communicated to the subgrantee and to the applicable MDHS Programmatic Funding Division in
a written notice.
Discovery of Possible Fraud, Mismanagement, or Program Abuse
If an allegation or suspicion of fraud, waste mismanagement, and/or program abuse is discovered
while conducting a monitoring review, the subgrantee will be referred to the Office of Inspector
General (OIG) for further investigation.
Subgrantees shall report any suspected fraud, waste and/or abuse to the Office of Inspector
General. The Office of Inspector General accepts tips and complaints regarding potential fraud,
waste and/or abuse in the following ways:
• Phone – 1-800-299-6905;
• Email – fraud@mdhs.ms.gov; and
• MDHS Fraud Tip Form located at https://www.mdhs.ms.gov/report-fraud/.
GRANTEE Mississippi
FFY 24
Division of Community Services (DCS)
Statutory Reference 2605(b)(10)
TRAINING & TECHNICAL ASSISTANCE (T&TA)
DCS staff uses several tools and checklists to conduct an overall comprehensive review of the
agencies’ operations. Throughout both the programmatic and fiscal review process there should
be ongoing, open communication with the staff to facilitate clarification of facts and prevent
misunderstandings, provide the reviewer with a full understanding of the agencies’ operations, and
provide the agency with a full understanding of the review process.
Preliminary areas of noncompliance should be summarized and discussed with the Executive
Director and/or designated staff during the exit conference. Copies of specific documents,
supporting schedules, and reports obtained during the site visit to facilitate preparation of the report
should be discussed during the exit conference. The agency is given the opportunity to provide
comments and present additional information or explanation regarding a specific finding before it
is included in the report.
The report should include specific timelines for any required corrective action associated with each
finding. Copies of the report should be mailed to agency’s Board and the agency’s Executive
Director. A copy should also be provided to the DCS Program Director and Compliance Officer.
The agency is required to respond in writing to each of the findings and observations mentioned
in the report, including a detailed plan for taking corrective actions and implementing required
changes. The initial response is due within 30 days from the date of the report. The agency’s plan
for resolution and corrective action will be reviewed by Compliance Team to ensure that all
findings have been adequately addressed.
In the event an agency is unable or unwilling to correct a specified area of noncompliance within
the prescribed timeline, DCS will report the deficiency to MDHS-Inspector General. If MDHS
determines that the agency remains noncompliance in a specified area, DCS may contact DHHS
to initiate proceedings to terminate the organization’s designation as a Community Action Agency.
GRANTEE Mississippi
FFY 24
ATTACHMENT-FAIR HEARING PROCESS
Statutory Reference 2605(b)(13)
3) Some issues are not subject to fair hearings, in which includes but not limited to, a
subgrantee failing to have enough funds for the county that the applicant resides
in. In this case, said subgrantee should refer applicant(s) to other social service
providers, or use non-federal funds if available. If a county runs out of funds
before the end of the program year, said subgrantee must maintain a list of
applicants who could not be served. These applicants must receive priority when
scheduling appointments at the start of the new program year or if additional
funds are awarded.
C. Appeal to the Subgrantee Level
1) After having exhausted all channels of resolution with the Executive Director of
the Subgrantee, the applicant or recipient must submit a written request for a fair
GRANTEE Mississippi
FFY 24
hearing to the subgrantee Board of Directors within thirty (30) calendar days that
the adverse action occurred. The written request must include the following:
a. Name and address of applicant or recipient,
b.Name of subgrantee,
c. Date of denial notice or adverse action taken,
d.Reason for said action,
e. Justification stating why action should not be taken,
f. Statement requesting a fair hearing, and
g.Two (2) signed and dated copies of the request (original and one copy).
2) Upon receipt of the applicant or recipient’s request, the subgrantee Board of
Directors must set the date of the fair hearing for the next scheduled board
meeting. The fair hearing will be conducted at the discretion of the Board of
Directors for the subgrantee. Said board shall render a written decision within five
(5) business days of the fair hearing date.
D. Appeal to MDHS
1) Written Appeal to MDHS for Fair Hearing: After having exhausted all channels
for resolution at the subgrantee level, the applicant or recipient has thirty (30)
calendar days from the date of the subgrantee Board of Directors’ decision letter
to submit a written request. The written request must include a copy of the
original hearing request and the Board of Directors’ decision letter. The request
should be submitted to:
Mississippi Department of Human Services
Director of Administrative Hearings
Post Office Box 352
Jackson, Mississippi 39205
2) Notice for the Fair Hearing: The recipient or applicant and subgrantee shall
receive written notice of the hearing, in which will include a statement of the date
and time the hearing is to be held. The hearing may be held telephonically unless
a face-to-face hearing is requested. A fair hearing shall be scheduled within seven
(7) calendar days the Director of Administrative Hearings receives a proper
written request.
3) Evidence and/or Documents: All documents relating to any pending proceeding
must be submitted to the Director of Administrative Hearings Division of MDHS
at the address listed above.
4) Informal Disposition: Informal disposition may be made of any case by written
stipulation, agreed settlement, consent order, or default.
GRANTEE Mississippi
FFY 24
5) Postponement/Continuance: The hearing officer may grant a postponement or a
continuance of the fair hearing for good cause based upon a written, advanced
request by either party.
6) Conduct of Fair Hearings: Subject to the hearing officer’s ruling and
recommended decision, opportunity must be given to all parties to respond,
present evidence, argue all issues involved and call witnesses. A recording of each
fair hearing should be made. If a party fails to appear, it may forfeit all rights.
7) Order of Hearing: The hearing officer calls the fair hearing to order; introduces
himself/herself and gives a brief statement of the nature of the proceeding; states
what documents the record contains; calls for opening statements by each party;
questions witnesses at will, and adjourns the fair hearing after all evidence has
been presented. During testimony, the applicant, recipient or subgrantee’s
representative(s) may question witnesses, cross-examine the other party’s
witnesses, and redirect if necessary.
8) Recommended Decisions and Final Decisions The hearing officer shall have the
responsibility of preparing a statement summarizing the facts brought out in the
fair hearing, indicating the policy governing the issue at hand, and making a
recommended decision based on the evidence presented. The recommended
decision shall be based only on evidence, testimony, and documents presented at
the fair hearing. Following the fair hearing adjournment, the hearing officer will
forward, both the record and recommended decision, to the MDHS Executive
Director for adoption, modification, or reversal. The final decision of the MDHS
Executive Director will be forwarded to the recipient or applicant along with the
Executive Director of the subgrantee. The decision of the MDHS Executive
Director shall be final and binding. The recipient or applicant has exhausted all
administrative appeals after the decision from the MDHS Executive Director has
been rendered.
E. Appeal to U.S. Department of Health and Human Services
1) If the final MDHS decision is not satisfactory, the applicant or recipient has ten
(10) calendar days to submit a written request to U.S. Department of Health and
Human Services. Said request should be sent to:
Secretary
U.S. Department of Health and Human Services
Office of Community Services
370 L’Enfant Promenade, S.W., 5th Floor
Washington, D.C. 20449
GRANTEE Mississippi
FFY 24
2) The written request must include a copy of the original hearing request, the Board
of Directors’ decision letter, and the final decision from MDHS. A decision
and/or hearing will be issued and/or conducted based on the discretion of the U.S.
Department of Health and Human Services.
3) Note: If at any point during the fair hearings process the original adverse action or
denial decision is overturned, the proper actions will be taken by the subgrantee.
Source: Miss. Code Ann. § 43-1-2(4); Miss. Code Ann. § 43-1-4
Revised: May 2022
GRANTEE Mississippi
FFY 24
ATTACHMENT - LIHEAP STATE PLAN PERFORMANCE MEASURES
The state of MS updated its centralized client tracking system (Virtual ROMA 2 (VR2) to
capture, analyze and submit information regarding energy burden targeting,
restoration/prevention of loss of home energy service. We signed vendor agreements to include
performance language, new performance related fields in VR system to allow collection and
reporting of energy information required to produce the performance report and identify high
energy users.
During the coming federal fiscal year, we plan to accomplish successful targeting of clients with
high energy burdens. Additionally, we plan to utilize the benefit targeting/reduction indices to
designate users who are high energy and allow for greater LIHEAP benefits and modify our
benefit matrix beyond income. We will partner with our top vendors to get performance
information more frequently. Presently, we are getting this information on an annual basis.
A vendor meeting will be scheduled to discuss results of the Performance Measures Report and
to obtain greater participation from all energy vendors. We were able to capture information
from the more propane vendors for this year’s report.
GRANTEE Mississippi
FFY 24
ATTACHMENT- WASTE, FRAUD & ABUSE
The Mississippi Department of Human Services has a zero tolerance for the commission or
concealment of acts of waste, fraud and abuse. Allegations of such acts will be investigated and
pursued to their logical conclusion, including legal action when warranted.
A. Waste involves the taxpayers not receiving a reasonable value for money in connection
with any government funded activities due to an inappropriate act or omission by players
with control over or access to government resources.
B. Fraud is a type of illegal act involving the obtaining of something of value through
willful misrepresentation or a false representation of a material fact, whether by words or
by conduct, by false or misleading allegations, or by concealment of that which should
have been disclosed, which deceives another so that he acts, or fails to act to his
detriment.
C. Abuse involves behavior that is deficient or improper when compared with behavior that
a prudent person would consider reasonable and necessary business practice given the
facts and circumstances. Abuse also includes misuse of authority or position for personal
financial interests or those of an immediate or close family member or business associate.
D. Types of Waste and Abuse include, but are not limited to:
1) Employee- Omitting client information, ghost clients, charging application fees,
former employee having access to software, receiving kickback from vendor, etc.
2) Client- Misrepresenting household size or income, falsifying application, forging
documents needed to complete intake, etc.
3) Vendor/Contractor- Charging a higher amount than the lowest allowable,
doctoring delivery tickets, providing financial incentive to staff to overlook
unallowable charges, double charges, incorrect pricing, etc.
E. Reporting Related to Waste, Fraud, and Abuse
1) Employee (MDHS) - Any employee who has knowledge of waste, fraud or abuse,
or has a good reason to suspect that such conduct has occurred, shall adhere to
this policy. When suspected fraudulent activity, waste, or abuse is observed by,
or made known to an employee, the employee shall immediately report the
activity to their direct supervisor. If the employee believes that the supervisor is
involved with the activity, they shall immediately report the activity to the
Division of Community Services’ Director. If the employee believes that the
GRANTEE Mississippi
FFY 24
Division Director may be involved with the activity, the employee shall report the
activity to the Office of Inspector General at 1-800-299-6905.
2) Employee (Subgrantee) - Any employee who has knowledge of waste, fraud or
abuse, or has a good reason to suspect that such conduct has occurred, shall
adhere to the procedure in this policy. When suspected fraudulent activity, waste,
or abuse is observed by, or made known to, an employee, the employee shall
immediately report the activity to his/her direct supervisor. If the employee
believes that the supervisor is involved with the activity, s/he shall immediately
report the activity to the Executive Director. If the employee believes that the
Executive Director may be involved with the activity, the employee shall report
the activity to the Board of Directors. If it is believed that the Board is involved,
it shall be reported to the Office of Inspector General at 1-800-299-6905.
3) Client or General Public - DCS cannot compel citizens and clients to report
suspected instances of waste, fraud and abuse. DCS, however, strongly
encourages citizens and clients to report such. Once management at the
subgrantee level or at the state level has been informed of suspected waste, fraud
or abuse, management shall provide the client with the established procedures for
filing a report. The Office of Inspector General may be contacted at 1-800-299-
6905.
4) Vendor - Any citizens, customer, vendor or agency that has knowledge of waste,
fraud or abuse, or has a good reason to suspect that such conduct has occurred
should report the occurrence to the Office of Inspector General at 1-800-299-6905
and may result in an investigation being conducted.
5) A confidential report may be submitted through the Virtual Roma website found
on https://virtualroma.mdhs.ms.gov. If the reporting party does not have access to
this system, reporting may be completed at the following contact information:
Call toll free number: 1-800-299-6905
Fax number: 601- 359- 5047
Address: Office of Inspector General
200 South Lamar Street
Jackson, MS 39201
6) Providing specific occurrence details of suspected waste, fraud, and abuse will
expedite investigative efforts. There is no requirement to submit identifying
information from those who wish to report suspected waste, fraud, and abuse.
7) Tips will be investigated in the order that they have been received with no
preference given to those who provided identifying information.
GRANTEE Mississippi
FFY 24
F. Penalties for Substantiated Waste, Fraud, and Abuse- Once an investigation has been
completed and reviewed by MDHS Office of Inspector General, penalties may be
enforced as follows:
1) Employee - Employees of MDHS or Subgrantee who have been found guilty of
waste, fraud and abuse are subject to prosecution and/or recoupment of any
benefits provided, following due process as defined in subgrantee regulations and
may be terminated.
2) Client - If it is the client’s first offense they will be ineligible for services for an
entire year from the date of the decision and benefits recouped. If it is the client’s
second offense, they will be disqualified permanently from the program and is
subject to prosecution and/or recoupment of any benefits provided, following due
process as defined in agency regulations.
3) Vendors and Contractors - Vendors/Contractors suspected of fraud and/or
misrepresentation may be suspended from participation and may be subject to
prosecution and/or recoupment of any benefits provided, following due process as
defined in agency regulations.