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Empire Justice Comments to OTDA on the 2014 -15 HEAP State Plan

August 19, 2014


Office of Temporary and Disability Assistance HEAP Bureau
40 North Pearl Street, 11B
Albany, New York 12243

RE:  Proposed NYS Plan for the 2014-2015 Home Energy Assistance Program (HEAP)

Dear OTDA personnel:

Thank you for the opportunity to comment on the proposed state HEAP plan for 2014-2015.

Empire Justice Center is a not for profit public interest law firm focusing on civil legal services for low income individuals.  In addition to litigation and policy analysis, we support legal services programs across the state with training and support and act as an informational clearinghouse.  We focus on a number of issues affecting low income individuals and families: public benefits (cash assistance, child care, SNAP and child support issues), health and Medicaid, Supplemental Security Income (SSI) and Social Security Disability (SSD) benefits, consumer and foreclosure prevention, and public and subsidized housing.

We are grateful that OTDA is proposing to continue the $21 “heat and eat” HEAP benefit for certain households residing in public/subsidized housing and group homes.  We strongly support the continuation of the $21 benefit, which allows these households to continue receiving a heating/cooling standard utility allowance (SUA) in their SNAP budget.  Receipt of the $21 HEAP benefit will prevent approximately 300,000 vulnerable SNAP recipients from facing a huge cut in their monthly SNAP budget.

Reduced federal funding has, by necessity, forced OTDA to make some tough decisions, both in lowered benefit levels and a shorter HEAP season.

We are concerned, though, that the very short timeframe to apply for regular HEAP (11/17/2014 through 12/31/2014, one month shorter than last year) is going to create significant hardship for districts/certifiers and clients, and we question whether districts have the capacity to adequately serve HEAP applicants in such a short timeframe.  We hear frequently that certifiers find it very challenging to deal with the crush of applicants who show up at their door when HEAP season opens.  Clients have told us that they have to make return visits and miss time from work when they can’t be seen the same day they try to apply.  The HEAP season already coincides with Medicare Part D open enrollment (Oct 15 – Dec 7), which is an extremely busy time for local Offices for the Aging (certifiers) and for Medicare recipients.   Many districts have reduced staff during Thanksgiving week and the last week of December due to the holidays/school vacation.

New York State should do everything in its power to keep the regular HEAP season open as long as possible, through at least the end of January, even if state dollars are required to do so.   

Thank you for your consideration of these comments.