Weather Assistance Program (WAP)

U.S. Department of Energy

Weatherization Assistance Program for
Low-Income Persons

APPLICATION INSTRUCTIONS

U.S. Department of Energy
Weatherization and Intergovernmental Program Office
1000 Independence Avenue, SW, EE-5W
Washington, DC 20585

December 2015

Table of Contents
Reference Page
List of Acronyms
I.
OVERVIEW
I.1
Introduction
II.
APPLICATION FOR FEDERAL ASSISTANCE - STANDARD FORM 424
III.

IV.

V.

VI.

BUDGET
III.1 SF 424A Budget Preparation
III.2 Budget Categories - Section B
III.3 Budget Justification
III.4 Carryover Explanation
ANNUAL FILE
IV.1 Subgrantees
IV.2 Production Schedule
IV.3 Energy Savings
IV.4 DOE-Funded Leveraging Activities
IV.5 Policy Advisory Council
IV.6 Hearings and Transcripts
IV.7 Miscellaneous
MASTER FILE
V.1
Eligibility
V.1.1 Approach to Determining Client Eligibility
V.1.2 Approach to Determining Building Eligibility
V.1.3 Definition of Children
V.1.4 Approach with Tribal Organizations
V.2
Selection of Areas to be Served
V.3
Priorities
V.4
Climatic Conditions
V.5
Type of Weatherization Work to be Done
V.5.1 Technical Guides and Materials
V.5.2 Energy Audit Procedures
V.5.3 Final Inspection
V.6
Weatherization Analysis of Effectiveness
V.7
Health & Safety
V.8
Program Management
V.8.1 Overview and Organization
V.8.2 Administrative Expenditure Limits
V.8.3 Monitoring Activities
V.8.4 Training & Technical Assistance
V.9
Energy Crisis & Disaster Response Plan
FEDERAL FINANCIAL REGULATIONS
VI.1 DOE Financial Assistance Rules
VI.2 OMB Cost Principles
VI.3 Financial Audits

Reference Page
Enabling Legislation
Federal Regulations
 Weatherization Assistance Program for Low Income Persons - 10 CFR 440
 Financial Assistance Rule - 2 CFR 200
 DOE Implementing Order - 10 CFR 1005
 Code of Federal Regulations (CFR)
 Federal Assistance Reporting Checklist - DOE F 4600.2 Economic Opportunity Act of
1964; Pub. L. No. 88-452, 42 U.S.C. § 2701 et seq
 Executive Order 12372 - Intergovernmental Review of Federal Programs
 2 CFR 200 Subpart E – Cost Principles
 2 CFR 200 Subpart F – Audit Requirements
 Federal Register
o Multifamily 50% threshold - 65 Fed. Reg. 77210, Dec. 8, 2000, Preamble
 Department of the Interior and Related Agencies Appropriations Bill. 1985 - House
Report 98-886
 Federal Register Notice, 45 Fed. Reg. 13028, 13031, Feb. 27, 1980
 Social Security Act, Pub.L. No. 88-452, 42 U.S.C. Ch. 7
 State Energy Efficiency Program Improvement Act of 1990 (SEEPIA) Public Law
101-440
Program Guidance
 Weatherization Program Notices
 Appendix A
Application Forms
 Performance and Accountability for Grants in Energy (PAGE)
o Standard Form 424 (SF-424) - Instructions
o Standard Form 424, 424A
o Standard Form LLL (SF-LLL) Disclosure of Lobbying Activities
o Quarterly Reporting:
 Federal Financial Status Report Standard Form 425
 Performance Report
o Annual Reporting:
 Training & Technical Assistance Activities
 Monitoring Activities
 Leveraging Updates
 Historic Preservation Report
Additional Resources
 Weatherization Assistance Program Technical Assistance Center – WAPTAC
 Oak Ridge National Laboratory - Weatherization
o National Evaluation of the Weatherization Assistance Program
 Weatherization Assistance Program Financial Management Tool Kit
 A Guide for State and Local Government Agencies: Cost Principles and Procedures for
Establishing Cost Allocation Plans and Indirect Cost Rates for Grants and Contracts with
the Federal Government
 ASHRAE 62.2-2013 – Available for purchase since April 2013

List of Acronyms
ACPU – Average Cost Per Dwelling Unit
ASHRAE – American Society of Heating, Refrigerating and Air-Conditioning Engineers
DOE – U.S. Department of Energy
FAO – Financial Assistance Office
GAO – General Accounting Office
HHS – U.S. Department of Health and Human Services
LIHEAP – Low Income Home Energy Assistance Program
OMB – Office of Management and Budget
PAC – Policy Advisory Council
PAGE – Performance and Accountability for Grants in Energy
POI – Pollution Occurrence Insurance
PVE – Petroleum Violation Escrow
QPR – Quarterly Performance Reports
The Recovery Act – American Recovery and Reinvestment Act of 2009
SEEPIA – State Energy Efficiency Program Improvement Act of 1990
SIR – Savings-to-Investment Ratio
T&TA – Training and Technical Assistance
WAP, Weatherization Program – Weatherization Assistance Program for Low-Income Persons
WAPTAC – Weatherization Assistance Program Technical Assistance Center
WPN – Weatherization Program Notice

ApplicationPackage
I.

OVERVIEW

I.1

Introduction

The Application Package is to be used by all States, Territories, and Indian tribes (and local
organizations, if applicable) as clarifying information when applying for direct grants under the
Weatherization Assistance Program for Low-Income Persons, administered by the U.S.
Department of Energy's (DOE), Weatherization and Intergovernmental Program, through DOE
Offices. Grantees shall comply with applicable law including regulations contained in 10 CFR
440, 2 CFR 200, and other procedures applicable to these regulations as DOE may, from timeto-time, prescribe for the administration of financial assistance. Any potential discrepancies
between information contained in this document and DOE regulations shall be resolved in
favor of DOE regulations.
Effective December 26, 2014, the DOE Financial Assistance regulations contained in 10 CFR 600
were superseded by the Financial Assistance regulations contained in 2 CFR 200 (with DOE
regulations specific to for-profit organizations codified in 2 CFR 910). WAP formula awards
originally issued for Program Year 2013 will be extended one additional year to Program Year
2016, and the award Special Terms and Conditions will be updated to require compliance with 2
CFR 200 and 2 CFR 910. DOE requires compliance with 2 CFR 200 and 2 CFR 910 for awards
issued after December 26, 2014.
In the development, submission, and review of grant applications, the provisions of Executive
Order 12372 (Intergovernmental Review of Federal Programs) and the DOE Implementing
Order (10 CFR 1005) remain unchanged. As Grantees begin to formulate the State Plan (Plan),
DOE strongly urges Grantees to hold two meetings to increase public involvement and obtain
timely suggestions in developing their Application: one at the beginning of the planning
process, as well as the formal and required public hearing on the completed Plan.
Applications must be submitted through the Performance and Accountability for Grants in
Energy (PAGE) on-line system to be considered for award.
Follow the instructions in PAGE for “Revision”, so that you may copy last year’s application
and work from there.
The DOE Project Officers will work with the Grantees to ensure applications for continuation
awards or extensions to current active awards are properly entered in PAGE.
If you have questions regarding the application package in PAGE, please refer to the Help
Menu in PAGE or contact the PAGE hotline at PAGE-Hotline@ee.doe.gov or 1-866-4924546.
SF-LLL Disclosure of Lobbying Activities
If applicable, complete and attach the SF- LLL to the Application. The SF-LLL may be
found at http://www.whitehouse.gov/sites/default/files/omb/grants/sflllin.pdf.
Applicability: If any funds other than Federal appropriated funds have been paid or will be
paid to any person for influencing or attempting to influence an officer or employee of any
agency, a Member of Congress, an officer or employee of Congress, or an employee of a
Member of Congress in connection with the grant/cooperative agreement, you must
complete and submit Standard Form - LLL, "Disclosure Form to Report Lobbying.”
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The Application includes both mandatory and optional sections, see the table below for a
complete list. Mandatory sections must be completed in their entirety. Complete data and
information will result in expedient review and award. The Grantee shall notify the
Project Officer upon submission of the application package in PAGE. If sufficient progress
to negotiate the final State Plan Application is not being made, DOE reserves the right to
put a hold on the funds the Recipient can draw down under the Automated Standard
Application for Payments (ASAP) System. DOE does not guarantee or assume any
obligation to reimburse costs incurred in the performance of the agreement if the award is
not approved.
Applicants are required to attach all supporting documents to the SF-424 Application in
PAGE, including supporting documentation to specific sections within the Annual and
Master Files (e.g., Health and Safety Plan, Policy Advisory Committee minutes, Public
Hearing notes/transcripts, copies of Public Hearing notices, organization charts and other
supporting documents such as indirect rate agreements, A-133 Audits, SF-LLL (if
applicable), Budget and Budget Justification of Subrecipients managing the program on
behalf of the Grantee).
Applicants should not include tables or spreadsheets within the Annual and Master Files or
in the comments section of the SF-424A Budget.
Name of Document
SF-424 Application for Federal
Assistance

Format
Mandatory Forms
PAGE

File Name
N/A

SF 424A File - Budget Information
PAGE
N/A
for Non-Construction Programs
Budget Explanation
PAGE
N/A
Annual File
PAGE
N/A
Master File
PAGE
N/A
Required Attachments to the Application Package in PAGE (SF-424)
Health and Safety Plan (if not already
PDF
Health and Safety Plan
included in the Master File)
Public Hearing Transcript
Public Hearing
PDF
Transcript/Notes
Public Hearing Notice(s)
Public Hearing Notice(s)
PDF or other format
Demonstrating 10 Days Notice
PAC Meeting Minutes
PDF
PAC Meeting Minutes/Notes
Indirect Rate Agreement (if
Indirect Rate Agreement
PDF
applicable)
Explanation of Indirect Costs (if
Indirect Cost Explanation
PDF
applicable)
Cost Allocation Plan (if applicable)
PDF
Cost Allocation Plan
PDF (or provide a link
in the narrative
Single Audit
2 CFR 200 Subpart F, Single Audit
comment section of the
budget)
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SF-LLL Disclosure of Lobbying
Activities (if applicable)
SF-424A budget for Subrecipient
managing the program on behalf of
the State (if applicable)
Budget Justification for Subrecipient
managing the program on behalf of
the State (if applicable)
WAP Organizational Charts(s)
Corrective Action/Removal
Procedures
Technical Monitoring Instrument
Administrative/fiscal Monitoring
Instrument

PDF

SF-LLL

PDF or other format

Subrecipient Budget

PDF or other format

Subrecipient Budget
Justification

Optional Forms
PDF
PDF or other format
PDF or other format
PDF or other format

WAP Org Charts
Corrective Action Removal
Procedures
Technical Monitoring
Instrument
Administrative/fiscal
Monitoring Instrument

DOE reserves the right to request additional or clarifying information for any reason deemed
necessary.

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ApplicationPackage
II.

APPLICATION FOR FEDERAL ASSISTANCE - STANDARD FORM 424

A completed and signed Standard Form 424 (SF-424) is required from each agency applying
for Federal funding under the U.S. Department of Energy's Weatherization Assistance Program
for Low-Income Persons. Please note that SF-424 is required when applying for new or
continuation funding allocations (Federal and non-Federal). The SF-424 is not required for
budget modifications that do not change the overall budget. When starting to complete the SF424 form in PAGE, please make sure you select “Continuation” under Field 2 - Type of
Application so the current grant is continued into 2016.

Only new funding allocations for the current year, and other current funding sources (if
applicable), should be identified in Block 18 – Estimated Funding. Do not include any
carryover funds in Block 18 or elsewhere within the SF-424 Application. Carryover
funds may not be transferred from other awards. The list of certifications and assurances
referenced in PAGE for Field 21 can be found on the DOE Financial Assistance Forms Page at
http://energy.gov/management/downloads/certifications-and-assurances-use-sf-424.
DOE requires Grantees to only check off the **I AGREE box in Field 21 in PAGE to comply
with the certifications and assurances. Grantees are not required to submit hard copies
documents.

INSTRUCTIONS TO ATTACH FILES:
All supporting documentation should be added as attachments to the SF-424. To attach a
document, go to the attachments section at the bottom of the SF-424 and click on the Browse
button. Find the file you want to upload and click the Open button. Click the Upload button to
attach the file to the application. When you have completed the upload process click Save.

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III. BUDGET
Two budget forms, the Standard Form 424A (SF-424A) and the Budget Justification, work in
conjunction with one another to provide DOE a clear understanding of how the Grantee is
proposing the use of funds following the DOE rules and regulations. The following depicts the
relationship between the sections of the SF-424A and how that information flows into the
Budget Justification. The applicant must provide a separate SF-424A budget and Budget
Justification in whole dollars for any subrecipient that will manage the program on behalf
of the Grantee and provide these documents as attachments to the SF-424 application in
PAGE.
SF-424A Sections:
Section A:
Budget
Summary

Listing all funding sources
(new**, carryover**, and other
funding sources by line item).

Section B:
Budget
Categories

Breakdown of Section A by
required categories, providing a
column for each budgeted
component.

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Separate Budget Justification
Further detail breaking
down the Budget
Categories of 424A Section
B to outline how the
categorical funds are
broken down by object
class (e.g., personnel,
travel, etc.)

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DOE encourages Grantees to fully utilize the DOE funding in the program year
it is awarded to maximize the opportunity of achieving the Weatherization
mission.
New funds: Any funds being added to the award in an annual budget period are new
funds, whether DOE or non-DOE.
Carryover: Any funds in the award that are not expended by the end of the budget
period are carryover funds. Grantees shall reasonably project unexpended balances
by Budget Category (matching the total sum carryover from all previous years) and
provide reasoning for why the funds are unlikely to be used by the end of the
program year. Grantees planning to carryover unused funds from any Budget
Category (i.e. training and technical assistance funds) from one program year to
another must return these monies to the program operations budget category and use
them to weatherize additional homes unless the Grantee can justify to the DOE
Project Officer the necessity to carryover these funds into the new program year and
that they be included as a part of the new training and technical assistance budget.
Funds from prior grants are not permitted to be to be carried over into a new award. Those
funds must be expended per the rules of the award in which they are from.
Following the first year of a grant award, Grantees with Carryover (non-expended funds) shall
provide one document with the following information as an attachment to the SF-424
Application in PAGE:
o Break out of cost categories for total carryover amount for all prior years and
current active year (should equal total carryover amount in the proposed budget
for the new program year).
o Break out of cost categories for total carryover amount in the proposed budget
for the new program year.
o Reason for the carryover amount and justification for the re-allocated carryover
amounts.

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EXAMPLE
Grantee Name, Grant Number, Program Year
BUDGET COLUMN
HEADING

Grantee Administration
Subgrantee Administration
Grantee T&TA
Subgrantee T&TA
Program Operations
Health & Safety
Financial Audits
Liability Insurance
Totals

TOTAL PRIOR YEAR
& CURRENT ACTIVE
YEAR CARRYOVER
(Identify the Cost
Categories you are
moving the
funds from)

PROPOSED BUDGET
CARRYOVER
(Identify the Cost Categories
that you
are moving the funds to in
the proposed budget for
the new program year)

$20,000
$9,500
$14,000
$11,000
$35,000
$10,000
$500
$0
$100,000

$20,000
$7,500
$0
$0
$63,000
$9,500
$0
$0
$100,000

Reason for carryover amount: The $20,000 state database upgrade budgeted under Grantee
Administration was delayed for several months, and will be completed in the next program year.
Subgrantee Administration results from a local agency manager leaving. All training and technical
assistance (T&TA) goals were met with fewer resources than budgeted. Production at two local
agencies was affected by job changes, thus leaving $35,000 unspent in Program Operations and
$10,000 in Health & Safety.
Justification for carryover amount: Moved $20,000 in Grantee Administration to complete
database upgrade as previously proposed. $7,500 returned to Subgrantee Administration to complete
the remaining work. $25,000 in T&TA and $500 from Financial Audits carryover moved to Program
Operations to complete more homes. Based on the Grantee expenditure limit identified in WPN 11-6,
the proposed Health & Safety amount was adjusted to reflect the proposed remaining Program
Operations funding.

III.1 SF-424A Budget Preparation
The SF-424A budget shall be prepared, identifying the total amount of new funding
allocations, other funding sources for the current budget period, and any carryover from
previous years, when applicable. For this purpose, please complete the SF-424A in whole
dollars, which can be found in PAGE after beginning an application package. Applicants are
required to adhere to the restrictions put on expenditures of their funds based on regulations.
The proposed budget costs are estimated values and invoicing shall be calculated from actual
costs incurred for each of the cost categories. Federal payments to a grantee’s “contingency
reserve” are generally unallowable. Other contingency costs may be allowable with certain
restrictions; see 2 CFR 200.433 “Contingency Provisions”. The Grantee may request funds
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under any of the Object Class Categories as long as the item and amount are necessary to
perform the proposed work and meet all the criteria for allowability under the applicable
federal cost principles.
IMPORTANT: Items identified as direct costs to the project may not be duplicative of costs
included in the indirect pool that are the basis of any indirect rate applied for this project.
SF-424A - Section A: Budget Summary
In PAGE, add each funding source to the SF-424A that will be utilized during the current
program year. Funding Sources can be classified as Federal, Applicant, Local, Other,
Program Income, State, Petroleum Violation Escrow (PVE), or 3rd Party Contributions.
When applicable, all carryover funds shall be identified under “Estimated Unobligated
Funds” while new funding shall be identified under “New/Revised Budget”. Each funding
source should be listed as a separate line item, including any leveraged funds that will
follow DOE rules and requirements.
o Grantee shall include as a separate line item for any leveraged funds to be used
in combination with DOE funds for weatherization activities. Most commonly,
Grantees add non-DOE resources into the award budget to access additional
administrative funds and complete additional homes following the DOE process
and procedures.
Leveraged funds identified in the budget and incorporated into the DOE award
must meet all DOE rules, regulations and guidelines. Leveraged funds that run
parallel or outside the DOE award (not included in the DOE budget) have
greater flexibility.
o Leveraged funds can come from several sources:

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

Appropriated Weatherization Funding



Low Income Home Energy Assistance Program (LIHEAP)



Leveraged Resources



Petroleum Violation Escrow (PVE) Funds



Program Income

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Below are specific aspects (both advantages and challenges) Grantees should keep in mind
when considering whether or not to include leveraged funds in both the SF-424 Application
and SF-424A Budget.
Advantages

Challenges

Leveraged
Funds
Included
in Budget

By including leveraged funds amount
in the budget, those funds are
calculated into administration
percentages and T&TA allocations,
giving the Grantee and Subgrantees
additional funds to administer the
leveraged resources and train staff.

Leveraged
Funds Not
Included in
Budget

A percentage of the grant can be used
to attract funds but the funds
leveraged do not have to follow all
DOE rules. Instead, these funds can
be used in parallel to the DOE
Program and funds can be allocated
for other activities not necessarily
justified by the audit or included in
Appendix A (e.g., house repairs
beyond the allowable incidental
repairs, replacing stand-alone
freezers, health and safety activities
that if not accomplished might result
in a deferral, etc.).

Must follow all DOE rules,
regulations and guidelines and
any measures installed using
these leveraged funds must be
justified by the audit/priority list,
follow DOE approved
procedures, and must be included
in the average cost calculation. As
such, the Grantee cannot use the
leveraged funds for any measures
or activities not justified by the
audit or included in Appendix A.
No additional % of funds can be used to
administer leveraged funds or be
allocated for T&TA if the leveraged
funds are not included in the DOE
budget.

III.2 Budget Categories – Section B
SF-424A - Section B: Budget Categories
The budget columns will be defined as Grantee Administration, Subgrantee
Administration, Grantee Training and Technical Assistance (T&TA), Subgrantee T&TA,
Program Operations, Vehicles and Equipment, Liability Insurance, Leveraging, Health &
Safety, Financial Audit, and Optional Categories. The ‘Total’ of Section A must equal the
total of all columns in Section B.
Object class categories will include Personnel, Fringe Benefits, Travel, Equipment,
Supplies, Contractual, Construction (not applicable to WAP), Other, and Indirect costs.
For Object class categories that relate solely to Subgrantee expenditures, the total estimated
cost should be reflected in the contractual category.
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A detailed justification and explanation for Grantee administration must be included, in
accordance with 10 CFR 440.12(b)(3). All amounts categorized as 'other' must be
supported with a detailed listing of items and costs.
The following supplemental instructions provide definitions and examples of the required
budget categories. The column and page notations in parentheses following each budget
category refer to Section B of Standard Form 424A.
Grantees should take note that in developing the budget, the requirement is for Grantees to
stay within the various budget category thresholds each year. While it may happen from
time to time that a specific cost category may “over run” in a particular year, these over
runs should be the exception, not the rule. Grantees should not approach the budget with
the expectation that they will catch up in the cost categories, particularly those with
regulatory or programmatic limits, at the end of the project period.
Administrative Categories
o 10 CFR 440.18(e) requires that the combined amount for both Grantee
Administration and Subgrantee Administration can be no more than 10 percent
of the total new funds to be awarded. However, the State Energy Efficiency
Program Improvement Act of 1990 (SEEPIA) Public Law 101-440, October 18,
1990, allowed a special provision for the Weatherization Assistance Program
and supersedes the 10 CFR 440.18(e) rule, with Congress allowing up to an
additional 5% of a Subgrantee’s award be used for administration if the
Subgrantee allocation is beneath a $350,000 threshold.
o Grantee must take care to only calculate NEW funds in determining the
administrative allowance as any carryover funds have already had
administrative costs allocated. Unexpended Funds in administrative category
accounts may be carried over from the previous budget period within the award,
provided there is sufficient support and justification for their continued use.
Grantees can also choose to include any administrative carryover funding
and/or provide a portion of their Grantee administrative funds to the local
providers.


The Weatherization Assistance Program legislation and regulations do not define
the Administrative Cost Categories. Any expenditure, allowable by Office of
Management and Budget (OMB) cost principles, by a Grantee or Subgrantee in
carrying out this Program may be charged as Administrative Costs. However,
certain costs in this Program, by exclusion from other categories, can only be
administrative.
Grantee Administration and Subgrantee Administration are considered to be
unique to each organization. The organization shall define its administrative costs
consistent with the generally-accepted accounting practices and procedures
within the organization.



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Indirect costs can be included in Grantee Administration and will be considered
an allowable cost provided there is a federally approved indirect rate(s) or cost
allocation plan. The rate/amount allowable does not invalidate the program
budget category limits.
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DOE has identified instances where certain administrative functions could be charged to
the Program Operations Category because of the nature of the expense as it related to
Program Operations (i.e., client intake, recordkeeping, salary/fringe of Program Managers
and coordinators, telephone costs, etc.). DOE encourages Grantees to allow their
Subgrantees to use this flexibility where it is appropriate. The Grantee must establish
uniform guidance to identify which funds may or may not be charged as Administrative
Costs.
Grantee Administration
o Amount can be no more than 5 percent of total new funds awarded. Cost
allocation between this category and Grantee T&TA must be in accordance
with 2 CFR 200 and 10 CFR 440.23 “Oversight, training, and technical
assistance.”
Subgrantee Administration
o Amount available for Subgrantees must be at least 5 percent of the total new
funds awarded.
o The Grantee may allow Subgrantees who receive less than $350,000 of new
DOE appropriated funds, to use up to an additional 5 percent of their
subgrants for administration. This is permitted only if the Grantee has
determined that such Subgrantee requires the additional amount to effectively
implement the administrative requirements of the Program.


Grantees shall develop criteria to be used when allowing these eligible
Subgrantees to use up to an additional 5 percent of their subgrants for
administrative purposes.

o The total effect of the additional 5% of administration costs may result in the
State exceeding the 10% administrative cost category for the award.
Tribes do not have the same limitation as States and Territories and are eligible for
both the Grantee and Subgrantee portion of Administrative funds.
Grantee T&TA and Subgrantee T&TA
o Maximum amount to be budgeted is included with the annual allocation
program notice from DOE.
o Allowable expenditures defined by 10 CFR 440 include:

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

Costs incurred in the training and technical assistance for any Grantee or
Subgrantee (including monitoring),



Providing information concerning conservation practices to occupants of
eligible dwelling units (client education),



Evaluation of Program outcomes,



Participation, travel, logistics of training activities and events,
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

Grantee purchases of vehicles or equipment, which are directly related to
specific training and technical assistance activities, such as monitoring,
etc.


T&TA funds shall not be used to purchase vehicles or equipment
for Subgrantees to perform Weatherization services. The cost of
these vehicles or equipment to support the Program must be
charged to the vehicle/equipment or program operations
categories.

Program Operations
Per 10 CFR 440.19, costs incurred for Program Operations are generally defined as the
direct costs necessary to effect the weatherization of an eligible dwelling unit but not
included in the material costs. While some of these categories could be charged as
allowable administrative or T&TA costs – depending on the nature of the expense – they
are almost always part of the ACPU calculation. Where there are costs that could be
charged to other Budget Categories, it is the determination of the Grantee which category
should be used. DOE expects that the Grantee will require consistency among its
Subgrantees when identifying a cost category other than Program Operations for these
specific charges. Many of these costs cannot be directly related to a specific dwelling unit
– like vehicle and equipment maintenance or purchases of tools and equipment. When
incurred, these total costs are amortized over the number of dwelling units completed
during the contract period. For example, the cost of a blower door ($4,500) could be
amortized over the 150 homes completed during a contract period, resulting in a $30
increase in the ACPU for the homes completed in that time frame.
Program Operations costs may include but are not limited to the following:
o Materials listed in Appendix A or as approved in audit protocol.
o Materials purchased for incidental repairs as defined in 10 CFR 440.
o Materials purchased for health and safety improvements.
NOTE: While health and safety costs are allowable under the Program Operations
category, DOE recommends Grantees include in the budget a separate health and
safety category.
o Transportation of weatherization materials, tools, equipment, and work crews to a
storage site and to the site of weatherization work.
o Maintenance, operation, and insurance of vehicles used to transport weatherization
materials.
o Maintenance of tools and equipment.
o Purchase or annual lease of tools, equipment, and vehicles.
NOTE: All vehicle purchases shall receive prior DOE approval; any equipment $5,000 or
more shall also receive prior DOE approval. Neither Grantees nor Subgrantees may prepay leases that exceed the end of the grant period.
o The required fees related to building permits from local governments are allowable
under this category.
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o Employment of personnel directly related to the operation of the Program:


This category is defined for general consistency purposes such as
weatherization coordinators' salary and fringe benefits spent in actual
supervision of labor, client intake, recordkeeping, etc.



Storage of weatherization materials, tools, equipment, and weatherization
vehicles.



Space rental. As with vehicles and equipment, neither Grantees nor
Subgrantees may pre-pay leases that exceed the end of the grant period.



Utility costs at storage only, i.e., heat, lights, and water.



Retrofitting storage facility.

NOTE: Weatherization is a non-construction program therefore no
construction of buildings or acquisition of real estate can be charged to this
grant. Improvements to a property that are not in direct relation to carrying
out Weatherization-specific tasks may not be considered allowable under this
grant (e.g., paving a parking lot of the storage area is not considered
allowable however retrofitting a storage facility with appropriate shelving to
accommodate supplies would be deemed allowable). Grantees should consult
with their respective Project Officer and/or DOE Grants Management
Specialist to clarify any areas of Grantee question or concern.
o Labor category expenditures are limited to those defined in 10 CFR 440.19.


Payments to employ labor or engage contractors including:


Payments to subcontractors;



Salaries and fringe benefits of crew members; and



Salaries and fringe benefits of crew leaders.



This category also includes auditors/assessors, quality control inspectors,
field supervisors who are not installing materials, and warehouse
personnel, such as inventory clerks, who are engaged in handling
materials.



Because T&TA funds are limited, Grantees and Subgrantees may charge
the cost of training to the T&TA category and the employee’s time for
participation in the event under the labor category.

o Other Optional Categories




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Special Project(s) (Column in PAGE but Grantees can designate a
specific purpose.)


Energy Crisis



Disaster Relief



Energy Audits

Low Cost/No Cost -- The cost of low-cost/no-cost materials is not to be
included in the average per unit cost (labor to install the low-cost/no-cost
materials is not an allowable cost). Details of any proposed low-cost/noJanuary 2016

ApplicationPackage
cost program component must be outlined in the plan following
guidelines in 10 CFR 440.18.
Health and Safety – Optional Category (Recommended)
o Indicate the amount of Federal funds to be used to mitigate energy-related
health and safety hazards, the elimination of which is necessary before, or
because of, installation of weatherization materials in accordance with 10 CFR
440.16(h) and 440.18(c)(15). The health and safety cost category should include
materials and labor, not training related to the implementation of health and
safety. Please refer to WPN 11-6 for allowable costs associate with health and
safety.
o Grantees must set health and safety expenditure limits for their Subgrantees,
providing justification by explaining the basis for setting these limits and
providing related historical experience. It is possible these limits may vary
depending upon conditions found in different geographical areas. These limits
must be expressed as a percentage of the average cost per dwelling unit
(ACPU). For example, if the average cost per dwelling is $5,000, 10 percent
would equal an average of $500 per dwelling unit for health and safety. These
funds are to be expended by Subgrantees in direct weatherization activities.


Up to 15% of Program Operations can be used for mitigating health and
safety concerns directly related to the weatherization of a building. DOE
considers this percentage reasonable and Project Officers can approve this
percentage with a sufficient explanation within the Health and Safety Plan
outlining what the Grantee will address.


Should a Grantee request to have 15% or more of Program
Operations used for health and safety purposes, DOE will conduct
a secondary level of review and may request additional
information to justify the higher percentage.

o The regulations do not mandate a separate health and safety budget cost
category, but rather encourages Grantees to budget health and safety costs as a
separate category and, thereby, exclude such costs from the average per-unit
cost calculation. This separate category also allows these costs to be isolated
from energy efficiency costs in program evaluations. If Grantees do not have a
separate health and safety budget category, Grantees are reminded that when
reporting these costs under the program operations category, the related health
and safety costs must be included in the calculation of the average cost per
home and cost-justified through the energy audit.
o Reference to current Health and Safety Guidance can be located in Section 5 of
the Annual Grant Guidance.
Vehicles and Equipment $5,000 or more – Optional Category
o In 2001, as an option, DOE created the Vehicles and Equipment budget
category so Grantees had a mechanism to allow Subgrantee amortization of
vehicle and equipment costs over multiple years. This can be particularly useful
to small Subgrantees that do not have alternative funding sources and are
unable to balance their production and average cost per home requirements
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when absorbing the vehicle or equipment costs over a single year. Alternatively,
vehicles and equipment may be expensed as a component of the Program
Operations budget category.
o If the Vehicle and Equipment category is proposed in the budget, the Grantee
takes on the additional responsibility of managing and reporting when costs
were expensed as well as how costs are amortized in the Quarterly Performance
Reports (QPR).
o If vehicles and equipment will not be purchased by the end of the program year,
DOE encourages Grantees to have provisions in the Subgrantee awards to allow
the use of the funding to complete additional homes and minimize unexpended
balances.
Liability Insurance – Optional Category (Recommended)
o All Grantees and Subgrantees must be covered by liability insurance. Liability
insurance refers to the general contractor, or other policies that provide
protection in case of personal injury or property damage resulting from the
weatherization services. Liability insurance can be charged to the liability line
item in the budget, which was created to ensure that such costs would not have
to be charged to the administrative cost category. See preamble to the Federal
Register Notice, 45Fed. Reg. 13028, 13031, Feb. 27, 1980.
o Alternatively, the cost of liability insurance is part of the ACPU when the
Grantee provides no allowance for the cost as a separate Budget Category in the
Grantee State Plan. Liability insurance is also part of the ACPU when private
contractors purchase policies as part of their service delivery requirements and
pass that cost through to the material and labor rates charged to install energy
efficiency measures. If the Grantee has a set-aside for Liability Insurance in
their State Plan, the Subgrantees can purchase policies and not include the
expense as part of their ACPU. This provision was established to cover general
agency liability insurance and does not include any vehicle related insurance.
o Most, if not all, regular liability insurance policies do not provide for many
health and safety measures such as lead and other pollution occurrence items.
Thus, DOE recommends Pollution Occurrence Insurance (POI) as a part of, or
an addendum to, general liability insurance. These costs are also charged on the
liability insurance line item. If Grantees or Subgrantees choose NOT to obtain
POI coverage and damage occurs or there is disturbance to any other
environmental pollutants, the cost of remediation, clean up, relocation, medical
expenses, or any other resulting costs may not be charged to DOE
Weatherization and must be covered by another funding source.
o DOE highly recommends that Grantees use the option of a separate budget line
item for Liability Insurance set-aside instead of including these insurance costs
within Grantee or Subgrantee administration or program operations line items.
Leveraging – Optional Category
o DOE Program regulations permit Grantees to take a percentage of their grant to
undertake leveraging activities which may supplement Weatherization or be
used to run a parallel Program (regardless of who initiates the action).
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Leveraging activities include paying for agency staff or hiring consultant staff
to explore and develop partnerships with utility companies and other entities
that will generate non-Federal resources for Weatherization. Other allowable
activities include:


Holding leveraging meetings, preparing technical materials/briefs, or
facilitating voluntary match funds from a non-Federal source.

o The leveraging column can consist of one or more leveraging activities.


Up to 15% of the annual Federal formula allocation (including PVE
funds used under the Weatherization Program) can be used for attracting
leverage resources. DOE considers this percentage reasonable for
leveraging activities that are in accordance with 10 CFR 440.14
(c)(6)(xiv). Project Officers can approve this percentage and related
purpose with appropriate explanation of activities to be conducted and
reasonable historic return on the investment.


Should a Grantee request to have more than 15% of their grant
used for leveraging purposes, DOE will conduct a secondary level
of review and will request additional information on the
anticipated return on investment to justify the higher percentage.

o If the Grantee chooses to add leveraged funds to the budget, identify the
following information for each third party contributing to the project: (1) the
name of the organization; (2) the proposed dollar amount to be provided; (3) the
amount as a percentage of the total project cost; and (4) the proposed leverage
item (cash, services, or property). By submitting an application that contains
leveraged funds, Grantees are providing assurance that the leveraged funds will
comply with all WAP rules, regulations and guidelines.
Financial Audit – Optional Category (Recommended)
Program financial audits are required by 10 CFR 440.23(d) and are allowable as either an
Administrative expense or as a separate Budget Category in the State Plan. In the past, the
cost of these audits was charged to the already over-burdened administrative cost category
and sometimes resulted in less than adequate, quality financial audits. Grantees are
encouraged to provide relief through the creation of a Financial Audit Budget Category,
thus allowing these charges to be covered when Subgrantees meet the threshold contained
in 2 CFR 200 Subpart F – Audit Requirements. If weatherization is one of several
programs within an agency being audited, only the fair-share proportion of the overall
financial audit costs should be charged to the DOE award.
NOTE: 2 CFR 200 Subpart F (State and local governments and non-profits) and
2 CFR 910 Subpart F (for-profit entities), should be consulted for thresholds, etc. and
additional questions should be directed to the Contracting Officer.
When a Grantee proposes using non-DOE resources off-budget to meet a DOE WAP requirement (i.e.
personnel costs for a required function, travel to a national DOE meeting) then a brief note by the
Grantee acknowledging commitment to the DOE requirement needs to be made. Such comments can
be provided in the corresponding Object Class Category of the Budget Justification. If comments
cannot be entered in the Budget Justification, then Section B of the SF-424A Budget is acceptable.
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III.3 Budget Justification
DOE Project Officers commonly focus on the information in the Budget Categories (columns)
of Section B of the Budget SF-424A in relation to the scope of work proposed in the Annual
and Master File. The Financial Assistance Office (FAO) staff at DOE responsible for
reviewing and approving the budget commonly focuses on whether the Grantee has included
sufficient detail and support for the information for the Object Class categories (lines) in
Section B of the budget. Clicking on the Section B line labels in PAGE (Personnel, Fringe
Benefits, Travel, etc.) accesses the budget justification detail.
An updated budget justification is required with each new budget proposed. Please note that
the total amount of funding for each Object Class category (i.e. Personnel) in the budget
justification screens needs to equal the total for that corresponding object class category in
Section B of the SF-424A budget. Grantees must provide their best and current estimate of
each budget category at the time of submittal.
If a Grantee secures approval from DOE that allows another entity to administer activities and
provide oversight of the Program, a separate and complete SF-424A Budget and Budget
Justification for that subrecipient is also required to be attached to the SF-424 application
submitted to DOE in PAGE. The Grantee is still overall responsible to DOE for the
administration and oversight of the Program, and all deliverables associated with the award.
Personnel
Grantees shall review and adjust staffing, description of responsibilities, salaries, hours or
percentage proposed over the next budget period to assure sufficient and appropriate
stewardship of the DOE funds. The listed costs are solely for employees of the Grantee.
Applicants shall identify positions to be supported and any key personnel should be
identified by title. All other personnel should be identified either by title or a group
category. State the amount of time (e.g., hours or % of time) to be expended, the composite
base pay rate, total direct personnel compensation and identify the rate basis (e.g., actual
salary, labor distribution report, technical estimate, state civil service rates, etc.). Identify
the number of employees (on a Full Time Equivalent) that will be employed in each
position or group category. Explain when staff time does not add up to 100% and indicate
when other funding will pay for time spent on DOE work.
Fringe
A federally approved fringe benefit rate agreement, or a proposed rate supported and
agreed upon by DOE for estimating purposes is required if reimbursement for fringe
benefits is requested. If a fringe benefit rate has been negotiated with, or approved by, a
federal government agency, a copy of the latest rate agreement must be included with this
application. If there is not a current, federally approved rate agreement negotiated and
available, provide a copy of the proposal with the application. If selected, the rate
agreement will be finalized during award negotiations. Calculate the fringe rate and enter
the total amount in Section B, line 6.b. (“Fringe Benefits”) of form SF-424A.
IMPORTANT: Grantees must provide all fringe rates, along with a complete explanation
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and the full calculations used to derive the total fringe costs. If the total fringe costs are a
cumulative amount of more than one calculation or rate application, the explanation and
calculations should identify all rates used, along with the base they were applied to (and
how the base was derived), and a total for each (along with grand total). The rates and how
they are applied should not be averaged to get one fringe rate.
Travel
DOE not only allows but expects Grantees to budget adequate funds to participate in
national and regional conferences, as well as participation on related planning committees,
task forces, and other scheduled and related meetings, and considers these meetings as high
priorities. DOE is aware that many Grantees have travel restrictions due to budgetary
constraints. Funds for Grantee and Subgrantee travel are provided as part of the
Weatherization grant award, and proper usage of these funds will be closely monitored by
DOE to ensure compliance with stated travel indicated in Grantees’ Annual Plans.
Additional travel may also be budgeted for in-state meetings, administrative, financial and
technical monitoring of Subgrantees, etc. Please provide the number of travelers, estimated
cost per traveler, duration of trip, and total cost per trip.
Proposed travel needs to clearly identify proposed activities and reflect sufficient
resources. DOE recognizes that many events and activities may require more than one
person from each state to sufficiently cover the amount of new information being
disseminated (e.g., a conference may have multiple tracks) and/or have sufficient expertise
(e.g., a single staff person may not have the skills to adequately monitor technical functions
and the administrative/financial elements).
Grantees should cite appropriate law, regulation or policy governing Grantee travel and
again, if an appropriate Grantee web link indicates per diems and process, please indicate it
in the narrative description.
Equipment
This category only covers equipment purchases at the Grantee level, not Subgrantee/vendor
level. Vehicles and equipment means tangible, nonexpendable, personal property having a
useful life of more than one year and an acquisition cost of $5,000 or more per unit. A
Grantee may use its own definition of vehicles and equipment provided that such definition
would at least include all equipment defined above.
All proposed equipment should be identified, providing a basis of cost such as vendor
quotes, catalog prices, prior invoices, etc., and briefly justifying its need as it applies to the
objectives of the award. Also indicate whether the Equipment is proposed to be used on
other projects or is 100% dedicated to the DOE project.
Materials and Supplies
Supplies are generally defined as an item with an acquisition cost of less than $5,000 and
in many, but not all cases have a useful life expectancy of less than one year. Supplies are
generally consumed during the project performance. Further definitions can be found in
2 CFR 200.
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Proposed supplies should be identified, providing a basis of cost such as vendor quotes,
catalog prices, prior invoices, etc., and briefly justifying the need for the supplies as they
apply to the objectives of the award. Note that supply costs identified, as direct costs in the
budget may not be duplicative of supply costs included in the indirect pool that is the basis
of the indirect rate applied for this project.
Grantees who propose the same copier and same server each year create a perception that
these items are placeholders as opposed to what the program truly needs and expects to
acquire in the upcoming budget period. Therefore, if a Grantee has a rotating IT
replacement type policy, provide supporting documentation as an attachment to the SF-424
Application and/or provide a web link to support the basis.
o For Grantees with Subgrantees: These are materials and supplies purchased for
use by the Grantee at the Grantee level and Grantees should make certain to
update annually based on program needs.
o For direct service provider Grantees (tribes and some territories): This
category will be different based on how the provider procures materials.
Grantees that are direct service providers should consult with their Project
Officer to determine appropriate cost category.
Contractual
The Grantee must provide and justify all costs related to Subgrantees and vendors
(including contractors, and consultants). The Grantee must provide a separate SF-424A
budget and Budget Justification for any subrecipient that will manage the Program on
behalf of the Grantee and provide these documents as attachments to the SF-424
application in PAGE.
o Subgrantees: The expected practice is a single line item that refers to and is
consistent with the Subgrantee Allocation table in Section IV.1 of the Annual
File.
o Vendors (includes contractors and consultants): The expected practice is to
identify each training center, training contractor, other program delivery
contracted services such as database development and management along with
the proposed budget amount. The support to justify vendor costs (in any
amount) should provide the purpose for the products or services and a basis of
the estimated costs that is considered sufficient for DOE evaluation.
If the effort/task has not already been procured, the vendor would be listed as
To Be Determined (TBD). It is helpful if this section indicates single-year
contracts/purchase orders, continuation, option year of a multiple year
procurement effort or otherwise.
Other Direct Costs
Other direct costs are direct cost items required for the project, which do not fit clearly into
other categories, and are not included in the indirect pool for which the indirect rate is
being applied to this project. This category is commonly used to capture rent, utilities,
phones, postage, association memberships, subscriptions, etc. that are weatherizationspecific direct charges to the award and that would not be appropriately categorized in
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other object class categories above. Include a basis of cost such as vendor quotes, prior
purchases of similar or like items, published price list, etc.
Grantees must include two specific statements as it relates to all Other Direct Cost items:
o All costs included in Other Direct Costs are properly segregated from indirect
costs to ensure there are not duplicate charges.
o All costs proposed are only being used in support of the WAP program.
Indirect Costs
Indirect costs are costs incurred for a common purpose, benefiting more than one program,
and not readily allocable among individual programs based on their proportionate shares of
benefits derived. A federally approved indirect rate agreement, or rate proposal supported
and agreed upon by DOE for estimating purposes, is required if reimbursement of indirect
benefits is requested. If there is a federally approved indirect rate agreement, a copy must
be provided with this application and if selected, must be provided electronically to the
Contracting Officer for this project. If there is no current, federally approved indirect rate
agreement or if the federally approved indirect rate agreement has been changed or
updated, a rate proposal must be included with the application. If selected, the rate
agreement will be finalized during award negotiations. Calculate the indirect rate dollars
and enter the total in the Section B., line 6.j. (Indirect Charges) of form SF-424A.
IMPORTANT: Provide a complete explanation and the full calculations used to derive the
total indirect costs. If the total indirect costs are a cumulative amount of more than one
calculation or rate application, the explanation and calculations should identify all rates
used, along with the base they were applied to (and how the base was derived), and a total
for each (along with grand total). The rates and how they are applied should not be
averaged to get one indirect cost percentage.
III.4 Carryover Explanation
Other than the first year of a new award, the Grantee shall include an explanation of any
estimated carryover amount by the budget categories (broken down by Grantee
Administration, Grantee T&TA, Subgrantee Administration, Program Operations, Health and
Safety, etc.) in which the funds are currently budgeted. The carryover explanation shall be
provided in a separate spreadsheet or other document attached to the SF-424 Application in
PAGE.
IV. ANNUAL FILE
IV.1 Subgrantees

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Some Grantee State Plans repeatedly indicate an ACPU that closely correlates to
the maximum $6500 (adjusted) DOE limitation. This reflects a minimum DOE
production requirement for the year, which is then often divided up and local
agency minimum production is estimated. Because the budget is also the basis
for reviewing other aspects (such as proposed Health & Safety costs) DOE would
like to improve the quality of Grantees’ production estimates. DOE has cause to
question the planning acumen of Grantees (and subsequently, Subgrantees) that
consistently exceed 150-200% of their production goal. Provide explanation if
ACPU estimate is significantly different from the actual ACPU reported for the
last Program Year.
In submitting the production schedule, Grantees shall thoroughly and
sufficiently support their proposed production estimates based on past reporting
as well as new implementation efforts (e.g. QWP).
The Grantee must identify all Subgrantees that will carry out the Program. Up-to-date information
required includes: name, address, DUNS number, contact person, type of organization (e.g., local
action agency, non-profit, tribal organization, or unit of local government), tentative allocation,
number of dwelling units (minimum one unit) expected to be weatherized during the program year, the
sources of labor, and the congressional district(s) and counties served.
IV.2 Production Schedule
This section must include the total number of dwelling units proposed to be weatherized under
the program rule with grant funds during the budget period for which assistance is to be
awarded, with financial assistance previously obligated under this part, and with the tentative
allocation to the Grantee. A completed production schedule will satisfy this requirement. The
form to be used for specifying the production schedule is included as part of the Annual File in
PAGE.
Grantees need to determine an Average Cost Per Dwelling Unit that correlates with their actual
production reporting. The production schedule has space to calculate the average cost per
dwelling unit for program operations, per 10 CFR 440.14(c)(6)(viii).
IV.3 Energy Savings
Applicants shall provide an estimate of the amount of energy to be conserved, pursuant to 10
CFR 440.14(c)(4). Grantees must indicate the methodology used to determine the energy
savings.
 DOE Algorithm


Other (describe as outlined below)

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DOE Algorithm:
For Grantees that have not developed a methodology for computing energy savings, applicants
can use the following formula:
DOE Program
Amount
Total DOE State Weatherization Allocation
Total Cost associated with Administration, T&TA, Financial and Energy Audits or
15%
of allocation
Subtract the amount entered in line (b) from line (a), for a total Federal (DOE)
funds available to weatherize homes
State Average Cost per Home or National WAP Program Year Average Cost per
Home
Divide the amount entered on line (c) by the amount entered on line (d), for Total
Estimated Homes to be Weatherized
Multiply (e) by 29.3 MBTU* for Total Annual Estimated Energy Savings resulting
from
DOE appropriated funds
All Funding Sources
Total funds (e.g., DOE WAP, State, Leveraged, LIHEAP, and other non-Federal
sources of funds) used by the Grantee to weatherize homes
Total cost associated with the administration of Weatherization funds or 15% of
total funds available to weatherize homes
Subtract the amount entered in line (h) from line (g), for total funds
available to weatherize homes
State Average Cost per Home or National WAP Program Year Average Cost per
Home
Divide the amount entered on line (i) by the amount entered on line (j), for Total
Estimated Homes to be
Multiply (k) by 29.3 MBTU* for Total Annual Estimated Energy Savings
resulting from all funding sources

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Line
(a)
(b)

(c)
(d)
(e)
(f)

(g)
(h)
(i)
(j)
(k)

(l)

ApplicationPackage
The most recently published evaluation of the Weatherization Assistance Program, specifically
the report “Weatherization Works – Summary of Findings from the Retrospective Evaluation of
the U.S. Department of Energy’s Weatherization Assistance Program”, ORNL/TM-2014/338,
estimates annual savings of 29.3 MBtu per year for natural gas heated homes. The study
includes site-built weatherized homes nationwide (which includes single-family homes and
buildings with 1-4 units, but excludes mobile homes and large multifamily). This value is
representative of the total energy savings expected from weatherization for an average house:
from the fuel used for space heating fuel (natural gas, propane, fuel oil, and electricity), which
may include water heating too, and the source value of the electricity savings for the house
(from space heating, space cooling, water heating, lighting, refrigerators, etc.
Other Methodology:
The estimate and the methodology used to estimate energy savings shall be clearly
explained including the information sources for energy savings per unit. Applicants shall
also quantify how much energy was saved in the preceding program year and compare it to
the estimate given last year.
DOE continues to encourage Grantees to proceed with individual Grantee evaluations.
Grantees undertaking such an evaluation are requested to coordinate their plans with DOE
so the information may be shared to gain maximum results from the Program. Technical
assistance is available to Grantees through DOE to help with the design and analysis plans
for Grantee evaluation studies. DOE published the report, “Estimating the National Effects
of the U.S. Department of Energy’s Weatherization Assistance Program with State-Level
Data: A Meta-Evaluation Using Studies from 1993 to 2005.” The individual evaluations
conducted by the Grantees were critical to this effort. Also, DOE completed a non-energy
benefits study. Both of these documents can be accessed on the ORNL website.
IV.4 DOE-Funded Leveraging Activities
In 1990, SEEPIA encouraged weatherization to consider an optional activity that may be
undertaken within the award.
Leveraging Partnership Development and Management: 10 CFR 440.14(c)(6)(xiv)
requires that Grantees provide the amount of Federal funds to be budgeted, and an
explanation of how they will be used, to increase the amount of weatherization assistance
to low-income clients. Leveraging means the obtaining by a state of additional programtargeted non-Federal cash or in-kind contributions as a result of the Weatherization
Program-funded activities. Up to 15% of the annual formula DOE allocation may be
proposed for leveraging and the application will still be eligible for the typical DOE
review. Applicants requesting a percentage higher that 15% will undergo secondary
review. Grantees may be required to provide more justification and documentation to
satisfy the more in depth review process. When the proposed costs are anything more than
incidental and beyond the capacity of the Grantee Administration category to cover within
its 5% budget limitation, then a new budget category (column) is created in the budget and
those costs need to be tracked separately.
Grantees shall provide an explanation of how these funds will be used to obtain nonFederal resources, how funds leveraged will be used to support the DOE Weatherization
Program, the leveraging effect of those funds, and the rationale for the amount of funds
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being used.
When using DOE funds, funds must be used to obtain non-Federal resources to: increase
the number of low-income homes weatherized, and/or increase the scope or type of
services provided to low-income homes. Grantees are encouraged to generate at least one
non-Federal leveraging dollar for every DOE dollar expended. Grantees shall provide
annual reports to DOE describing training, technical assistance, monitoring, and leveraging
activities that have occurred in the previous year. DOE realizes generating new leveraging
resources is not always immediately successful.
The Grantee, as well as the DOE Project Officer, is asked to review past performance and
determine after some reasonable period if the lost opportunity of weatherizing additional
homes with the DOE funds outweighs the continued budgeting and spending towards
unsuccessful leveraging efforts.
Leveraging Funds Implementation: In some limited cases, a Grantee may want to
consider including the actual leveraging funds as part of the DOE grant to access additional
Grantee administration resources. Although allowable, most Grantees carefully weigh the
additional responsibilities, reporting, constraints and DOE oversight and prefer to operate
the leveraged funds as an activity outside the DOE grant budget.
DOE is aware that reporting may be difficult where multiple sources of
funds are used to weatherize a unit or a complicated leveraging agreement
has been reached with non-Federal partners. To assist Grantees and
Subgrantees in determining what a DOE weatherized unit is, DOE offers the
following definition. A DOE Weatherized unit is: A dwelling on which a
DOE-approved energy audit or priority list has been applied and
weatherization work has been completed. As funds allow, the DOE
measures installed on this unit have a Savings-to-Investment Ratio (SIR)
of 1.0 or greater, but also may include any necessary energy-related
health and safety measures. The use of DOE funds on this unit may
include, but are not limited to auditing, testing, measure installation,
inspection, use of DOE equipment and/or vehicles, or if DOE provides the
training and/or administrative funds. Therefore, a dwelling unit that meets
both the definition of a DOE weatherized unit and has DOE funds used
directly on it must be counted as a DOE completed unit.
IV.5 Policy Advisory Council
A Policy Advisory Council (PAC) shall be established in accordance with 10 CFR 440.17. The
regulations reflect DOE’s intentions in offering Grantees some flexibility in the area of the
PAC. In order to change the PAC to a council or commission, the Grantee must show cause to
DOE that the current PAC is either non-existent or is not functioning as outlined in 10 CFR
440.17 of the Program regulations. DOE does not intend, nor does it mean to imply, that the
Grantee has the discretionary authority to replace the PAC without due process or cause.
Any Grantee who desires to substitute a Grantee council or commission for a PAC, must
address this issue as a part of the public hearing held regarding the annual State Plan. The DOE
Project Officer will make the final determination regarding this request as a part of the review
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of the application and State Plan.
Also, the requirement remains that any person(s) employed in any Grantee Weatherization
Program can be a member of an existing commission or council, but has to abstain in
reviewing and approving the activities associated with the DOE Weatherization Assistance
Program.
Provide the following details within the chart in PAGE (or in an attachment) when completing
the PAC section:
o Name of each person on the PAC
o Complete up-to-date contact information for each PAC member
o Name and the type of organization they represent (interests such as low-income,
elderly, persons with disabilities, Native Americans, utilities, etc.)
o Minutes from required PAC meetings related to the development of and
comment on the State Plan.
IV.6 Hearings and Transcripts
DOE reminds Grantees that pursuant to 10 CFR 440.14(a) before submitting an application to
DOE, a Grantee must provide at least 10 days’ notice of a hearing to inform prospective
Subgrantees of how they may obtain a copy of the proposed State Plan and must conduct one
or more public hearings to receive comments (verbal or written) on the proposed plan.
Historically, the notice has appeared in print publications. Given recent innovations in
technology, Grantees may use a Grantee-approved alternative electronic public notification
process that is used by other Federally-funded Grantee programs, provided it is also approved
by the DOE Project Officer in advance.
As part of the Hearings and Transcripts submission, the Grantee must identify how the notice
was provided to the prospective Subgrantees and public (e.g., a list of publications, publisher’s
affidavit when available, and/or copy of the notice(s) may be attached to the SF-424
Application in PAGE). DOE Project Officers will review the notice to ensure Grantee
compliance in notifying the public of where/how to obtain copies of the Plan. Most Grantees,
States, and Territories have laws governing the conduct of public hearings. If applicable, those
laws and requirements must be followed as well.
DOE strongly encourages the notice include a summary or highlights of the proposed changes
from the previous year’s Plan. The summary should also include any changes being proposed
in geographical services (e.g., how the Grantee may serve the entire state but on a rotating
basis), consolidation or rebidding of network providers, credentialing or training requirements,
etc. Providing this information in advance will improve communication between the Grantee
and Subgrantees and other interested parties and minimize disputes that may arise at the
hearing. Whenever possible, DOE would like to be informed in advance of significant
proposed program changes or issues of a contentious nature that will be addressed at the
hearing.
DOE no longer requires an official transcript of the public hearing but accepts adequate
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notes/minutes taken by a Grantee staff person. DOE still considers an official hearing
transcript as a best practice, particularly if the hearing is anticipated to propose significant
program changes or be contentious. If an official transcript is not taken, Grantees must submit
the notes or minutes taken by Grantee staff person and any comments received by the Grantee
on the minutes or notes from the hearing.
The Grantee shall attach minutes/notes from the hearing to the SF-424 Application in PAGE.
The DOE Project Officer will review the minutes of the public hearing(s) on the annual
Grantee Plan to determine that all issues are properly addressed by the Grantee prior to
approval of the final Grantee plan. If an official transcript is under development, Grantee
should attach notes to the SF-424 application in PAGE to inform DOE of any issues raised and
how the Grantee will address these issues. The official transcript should then be forwarded to
the DOE Project Officer upon completion.
Grantees should be aware that if significant program changes are made after the initial public
hearing(s), an additional hearing may be required. DOE encourages the inclusion of a
redistribution provision in the Plan to enable the Grantee to actively manage the grant and
move funds as necessary to fully expend the monies during the budget period. Vetting this
redistribution provision during the initial public hearing may negate the necessity of
performing subsequent hearings as long as the prescribed process for the redistribution of
funding in the DOE approved plan is followed.
IV.7 Miscellaneous
This section is available for Grantees to use as deemed appropriate for any activities that are
not routinely administered as part of the Weatherization Assistance Program or there is no
other section of the annual file specifically noted to describe the activities.
Recipient Business Officer and Recipient Principal Investigator
In the Annual File, at the beginning of the “Miscellaneous” Section, please identify the name,
email address, and phone number for the “Recipient Business Officer” and “Recipient
Principal Investigator”, as defined below. These personnel are the official Recipient points of
contact that will be identified in the Assistance Agreement, which is the authorizing award
document issued by the contracting officer. If the designated Recipient Business Officer or
Recipient Principal Investigator changes during the project period of performance, it is
incumbent upon the Grantee to notify the DOE Grants Management Specialist and DOE
Project Officer assigned to your award.
“Recipient Business Officer” is the representative authorized to act on behalf of the Grantee
to negotiate the award. All DOE official correspondence related to the award will be addressed
to the Recipient Business Officer.
“Recipient Principal Investigator” is the technical representative authorized to act on behalf
of the Grantee as project manager for the award. The Recipient Principal Investigator is the
prime point of contact for the DOE Project Officer during the project period of performance
and will receive a copy of all DOE official correspondence related to the award.

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V.

MASTER FILE

V.1 Eligibility
Every dwelling weatherized must meet both the client eligibility and the building eligibility
requirements.
V.1.1 Approach to Determining Client Eligibility
The definition of "low income" that the state has chosen for use statewide to determine
eligibility under §440.22(a) must be stated per §440.14(c)(6)(xii). Applicants should
briefly describe their procedures, in accordance with §440.16(a), to ensure that no dwelling
unit is weatherized without documentation that the unit is an eligible dwelling unit
(providing a copy of link to a Policy and Procedures Manual may satisfy this requirement).
Income Verification
In determining what eligibility level will be used in its program, the Grantee must verify
eligibility for weatherization assistance under this part. The dwelling unit is eligible for
assistance if it is occupied by a family unit:
o Whose income is at or below 200 percent of the poverty level determined in
accordance with criteria established by the Director of the Office of
Management and Budget, except that the Secretary may establish a higher level
if the Secretary, after consulting with the Secretary of Agriculture and the
Secretary of Health and Human Services, determines that such a higher level is
necessary to carry out the purposes of this part and is consistent with the
eligibility criteria established for the weatherization program under Section
222(a)(12) of the Economic Opportunity Act of 1964; , Pub. L. No. 88-452, 42
U.S.C. § 2701 et seq;


DOE distributes to Grantees, as made available, Poverty Income
Guidelines and Definition of Income. This document includes a revised
definition of income for use by Grantees and Subgrantees in their
programs. The revisions in this document include defining income, cash
receipts, exclusions, proving eligibility, child support, annualizing
income, and re-certification.



Grantees and Subgrantees are reminded that the supporting
documentation for applicants applying for weatherization that may be on
a waiting list or for other reasons must have their eligibility
documentation updated at least annually.

o Which contains a member who has received cash assistance payments during the
preceding twelve month-period under Titles IV and XVI of the Social Security
Act, Pub.L. No. 88-452, 42 U.S.C. § 2701 et seq. or applicable State or local law;
or
o If a Grantee elects, is eligible for assistance under the Low Income Home Energy
Assistance Act of 1981, provided that such basis is at least 200 percent of the
poverty level determined in accordance with criteria established by the Director of
the Office of Management and Budget.
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Income limits chosen may not be arbitrarily lowered by Grantee for parts of the Grantee
service territory. Indicate that application eligibility expires 12 months from certification date
if work on unit (audit) has not been initiated.
Information should describe the population within their state, or region that is eligible to
receive weatherization services. Priorities given to certain portions of the eligible
population should also be described
Qualified Aliens Eligibility for Benefits
Grantees are directed to review guidance provided by Health and Human Services (HHS)
under the Low Income Home Energy Assistance Program (LIHEAP). Grantee must submit
any policies or procedures in place to ensure DOE weatherization services shall only be
provided to eligible populations.
V.1.2 Approach to Determining Building Eligibility
Reweatherization
Grantees and Subgrantees may weatherize homes previously weatherized from September
30, 1994, and earlier. This provision gives Grantees the flexibility to revisit those homes
weatherized prior to 1994 that may not have received the full complement of
Weatherization services, including the use of an advanced energy audit or addressing
health and safety concerns. Describe Grantee process for tracking homes previously
weatherized since September 30, 1994, ensuring that these units are not reweatherized with
DOE funds. DOE reminds Grantees and Subgrantees that in selecting previously
weatherized homes to revisit, there still remain more than 39.5 million federally eligible
households that have received no Weatherization services to date.
In addition, DOE issued WPN 12-7 to address Disaster Planning and Relief, which
provides a framework for reweatherization of homes to occur on October 1, 1994, and later
due to natural disasters. Please refer to these sections and follow appropriate procedures if
the Grantee wishes to serve homes located in disaster areas.
NOTE: The term “Reweatherization” applies only to those units which fall into the
category of time indicated above and described under 10 CFR §440.18(e)(2)(iii).
Eligible Structures
Grantees should exercise caution in dealing with non-traditional type dwelling units such
as shelters, apartments over businesses, etc. to ensure they meet Program regulations on
whether the unit is, in fact, eligible. Consideration on weatherizing these types of units
should be discussed and if necessary, approved by the DOE Project Officer prior to
weatherization.
The weatherization of non-stationary campers and trailers that do not have a mailing
address associated with the eligible applicants is not allowed. The use of a post office box
for a non-stationary campers or trailers does not meet this requirement.
Provide a brief description of State Historic Preservation Officer (SHPO) Programmatic
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Agreement (PA) in place can be provided in this section,
http://energy.gov/eere/wipo/historic-preservation-executed-programmatic-agreements.
Rental Units
Applicants shall include in this section an explanation for how they will ensure that the
benefits of weatherization to occupants of rental units are protected in accordance with
§440.22(b)(3). Applicants are requested by the U.S. Department of Energy to satisfy this
requirement by developing and submitting rental plans or procedures that address
protection of renters' rights as specified in §440.22(b)(3) and §440.22(c)-(e).
Whether single-family or multifamily, the Grantee’s procedures for rental unit or rental
units shall ensure (include explanation of procedures):
o Written permission of the building owner or his/her agent before commencing
work.
o Benefits of the services accrue primarily to the low-income tenants residing in such
units.
o For a reasonable period of time after completion, the household will not be
subjected to rent increases (unless those increases are demonstrably related to other
matters other than the weatherization work performed).
 There are adequate procedures whereby the Grantee can receive tenant
complaints and owners can appeal, should rental increases occur.
o No undue or excessive enhancement shall occur to the value of the dwelling unit.
To secure the federal investment and to address issues of eviction from and sale of
property, per 10 CFR 440.22(c), Grantees may seek landlord agreement to placement of a
lien (or other contractual restrictions) upon the property being weatherized.
In the case of multifamily buildings, additional elements should include:
o Requirement of financial participation, when feasible, from owners of such
buildings.
o Explanation of Grantee plan for weatherization of MF buildings with 50%
income eligible units.

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Certain buildings containing rental units may comply with the income eligibility
requirements when 50 percent of those dwelling units are eligible dwelling units
rather than the established 66 percent identified in the regulation. (10
CFR§440.22(b)(2)). The buildings that are subject to the 50 percent threshold are
duplexes, four-unit buildings, and certain eligible types of large multifamily
buildings. In the final rule published on December 8, 2000, DOE provided guidance
on what types of large multifamily buildings may be subject to the 50 percent
threshold. (65 Fed. Reg. 77210, Dec. 8, 2000.).
DOE indicated that “certain eligible types of large multifamily buildings” are those
buildings for which an investment of DOE funds would result in a significant
energy-efficiency improvement because of the upgrades to equipment, energy
systems, common space, or the building shell. (Id. at 77215) By providing this
flexibility, Subgrantees are better able to select the most cost-effective investments
and enhance their partnership efforts in attracting leveraged funds and/or landlord
contributions. This flexibility does not apply to any other type of multifamily unit.
Questions on whether a building meets the criteria should be directed to the DOE
Project Officer.
The definition of “significant energy improvement” is based on specific criteria for
the building in question. This must be assessed using existing conditions to
determine the threshold to achieve significant energy improvements. Grantees
should consult with their DOE Project Officer if there are questions related to this
threshold.
NOTE: Grantee and Subgrantee agencies should exercise caution when utilizing
flexibility in this area. The key is the investment of DOE funds coupled with
leveraged resources, which result in significant energy savings. Absent this
investment, lowering the eligibility to 50% may lead to disallowed costs.
Subgrantees who are uncertain on a given multifamily project should seek
approval by the DOE Project Officer through their Grantee Weatherization
Program Manager.
DOE acknowledges the need to codify the practices and approaches necessary for
implementation of multifamily and rental unit weatherization. WPNs and FAQs on
Multifamily Weatherization and Weatherization of Rental Units are forthcoming for
PY 2016. These notices will supersede WPN 10-7 Revised Davis-Bacon Wage
Determinations for the Weatherization Assistance Program, WPN 11-9 Updated
Guidance on Eligible Multifamily Property Listings for Use in the Weatherization
Assistance Program, and The Renters Handbook for Weatherization Assistance
Program Grantees and Subgrantees dated January 27, 1984.
DOE previously issued the following Program Notices on multifamily related issues:
WPN 10-15, Final Rule on Amending Eligibility Provisions to Multifamily Buildings
for the Weatherization Assistance Program; WPN 10-15A, Guidance Regarding
Accrual of Benefits to Low-Income Tenants in Multifamily Buildings under the
Weatherization Assistance Program; and WPN 10-17, Guidance on Using NonFederal Resources as a Buy-Down for Meeting the Savings-to-Investment Ratio for
Materials Used in the Weatherization Assistance Program.
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Deferral
While clients may meet the eligibility requirements, it is important for Grantees to have
clear and concise directions for the Subgrantees as to when a building should be deferred
because the building is not a good candidate for weatherization. Provide a copy of these
requirements. Examples may include:
o Condition of the structure (building integrity/inability to practically or
effectively weatherize).
o Area slated to be redeveloped (highway development, economic development,
flood area).
o Health and safety reasons that defer services.
o Specifics on notification to client of deferral.
V.1.3 Definition of Children
The definition of "children," chosen by the Grantee and consistent with 10 CFR 440.3, that
the state has chosen shall be provided as required by 10 CFR 440.14(c)(6)(xiii). The
selection of age in the plan, then becomes the basis used for reporting
V.1.4 Approach to Tribal Organizations
Applicants shall include a statement, in accordance with 10 CFR 440.16(f), that lowincome members of an Indian tribe will receive benefits equivalent to the assistance
provided to other low-income persons within the state unless the applicant has made the
recommendation provided in 10 CFR 440.12(b)(5). In such a case, the applicant shall
provide a recommendation that a tribal organization be treated as a local applicant eligible
to submit an application pursuant to10 CFR 440.13(b), if such a recommendation is to be
made.
V.2 Selection of Areas to be Served
Applicants shall provide, per 10 CFR 440.14(c)(6)(ii), an explanation of the method used to
select each area to be served by a weatherization project.
V.3 Priorities
Grantees shall clearly describe procedures for any priorities given to certain portions of the
eligible population in receiving weatherization assistance. Specifically, as required by 10 CFR
440.16(b), briefly describe procedures Grantees and Subgrantees use to prioritize clients for
weatherization service. Grantees must develop a procedure to ensure that the following
applicant priority categories are addressed. Grantees have flexibility to determine how to
prioritize these areas:
o Elderly persons,
o Persons with disabilities,
o Families with children,
o High residential energy users, and
o Households with a high energy burden.
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The categories listed are the only allowable priorities for the DOE WAP. Grantees are also
expected to describe how applicants are drawn from a waiting list. The first consideration must
be by priority category. Grantees may choose to use oldest application certification date for
positioning applicants with the same category. Applications may also be given service with
timing to coordinate services with another funding source.
Consideration of “high residential energy users” and “households with a high energy burden”
(as defined in 10 CFR 440.3) may be in combination with, the other priority categories of
elderly, persons with disabilities, or families with children. The consideration of “high
residential energy users” and “households with a high energy burden,” allows Grantees and
Subgrantees to be better able to partner with utilities and other programs to leverage additional
resources into their programs. If a Grantee elects to use either of these categories, these should
be submitted in Program Reporting.
Housing type is not a recognized priority under the regulations, and use of housing type as a
priority may be contrary to the requirement for high residential energy users to be considered
as a priority in evaluating service delivery ranking of eligible households. Grantees and
Subgrantees may not discriminate due to the type of home where the low-income family lives.
All other issues related to eligibility (like the entire multifamily building being eligible for a
family to receive services) still apply.
V.4 Climatic Conditions
In this section, applicants must describe the climatic conditions within the state, including a
map or table showing the heating degree days and cooling degree days (if cooling measures are
considered) in each area served by a weatherization project. Weather data in units other than
heating and cooling degree days may be provided if desired. Sources of weather data are to be
listed. A brief explanation shall be given of how climatic variances within the state affect the
weatherization of eligible units (e.g., site-specific weather files used in computerized energy
audits).
V.5 Type of Weatherization Work to be Done
V.5.1 Technical Guides and Materials
Grantees must provide title and issue date for the documents used by Grantee and the
Subgrantees to determine work to be done. Grantee must ensure that all technical guides
and materials meet the specifications, objectives and desired outcomes outlined in the
Standard Work Specifications for Home Energy Upgrades (SWS) (refer to WPN 15-4,
Section 1, for additional details). These documents may include field guides, program
updates, procedures manuals, standards documents, etc.
o Grantees will provide an electronic link to, or an electronic copy of, their
current field guides and standards that have been reviewed and approved by
DOE for alignment with the SWS, as outlined in WPN 15-4.
o Grantees will provide documentation of the process for distribution of the field
guides and standards to Subgrantee agencies and direct hire contractors. (i.e.
how will the Grantee ensure that these materials are received by the appropriate
parties?)
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Provide a statement that all Subgrantee agreements and vendor contracts, will
contain language which clearly documents the SWS specifications for work quality
outlined in WPN 15-4, Section 2. Grantee must include a statement declaring all work is
being performed in accordance to the DOE-approved energy audit procedures and 10 CFR
440 Appendix A.
o Grantees must provide language to be included in Subgrantee contracts that
outlines the expectations for work quality and instructs the Subgrantee to
include these expectations in any contracts entered into with contractors and
vendors.
o Grantees must provide a description of the mechanism that will be used to
confirm that these expectations are understood and agreed to by any individual
or organization performing work with WAP funds. (i.e. will the Subgrantee
provide a signature on the contract documents as verification?)
V.5.2 Energy Audit Procedures
In accordance with 10 CFR 440.21 (i), all Grantees must resubmit their audit procedures
(and priority list(s), if applicable) to DOE for approval every five years. If the Grantee
audit procedures (and priority lists(s)) are not in compliance with this requirement, a
corrective action plan must be submitted with this grant application. Grantees should be
aware of the time consuming nature of resubmitting audit procedures and DOE approval
process. Grantee initiation of work on this process must allow time for the
development/approval process and field training for updated procedures so the revised
procedures are implemented prior to the five year expiration date. At minimum, the
Grantee must provide a statement in the State Plan indicating commitment to comply with
this requirement. DOE specifically requires energy audit procedures to be separately
developed and approved for use on single-family dwelling housing type and manufactured
home housing type. Detailed guidance is provided in WPN 13-5, Revised Energy Audit
Approval Procedures and Other Related Issues.
Single Family
Grantee must provide a date of last approval for both the energy audit process and priority
list(s), if applicable, including H&S protocols. If re-approval is within this PY, Grantee
should identify in the comment box what planning is underway to get re-approval in place
and the estimated date of submission.
Manufactured Housing
Grantee must provide a date of last approval for both the audit tool and priority list(s), if
applicable. If re-approval is within this PY, Grantee should identify in the comment box
what planning is underway to get re-approval in place and the estimated date of
submission.

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Multifamily
Where multifamily dwelling units represent more than 20% of a Grantee’s building type,
DOE requires the Grantee to submit multifamily audit procedures. For Grantees that fall
below the 20% threshold and do not have a DOE-approved audit and procedures for
multifamily buildings, a Grantee must take two actions:
o Describe in the State Plan the approach that will be taken to ensure that the
eligible occupants of multifamily dwellings receive appropriate, cost-effective
weatherization services.
o At the time a MF project is considered, the Grantee must submit to the Project
Officer the necessary material to approve the multifamily project prior to
commencing weatherizing the building (e.g. engineering assessment, audit
input/output). The Project Officer will review and approve the project(s) on a
case-by-case basis in the absence of a multifamily energy audit.
If a Grantee has a multi-protocol approved, the Grantee should provide the date of last
approval. If the Grantee does not have a multi-protocol approved, please estimate in the
comment box what % of the units the Grantee weatherizes are multifamily, describe what
approach the Grantee will take to ensure this housing stock is served, and provide a
statement to verify the Grantee understanding of process to be followed to have projects
approved on a case-by- case basis.
V.5.3 Final Inspection
Grantees shall describe their procedures to ensure that no dwelling unit is reported to DOE
as completed until all weatherization measures have been installed and the Subgrantee, or
its authorized representative, has performed a final inspection(s) including any mechanical
work performed and certified that the work has been completed in a workmanlike manner
and in accordance with the priority determined by the audit procedures required by 10 CFR
440.21.
Grantees must ensure that all Subgrantee final inspections for completions are performed
by certified Quality Control Inspectors as outlined in WPN 15-4 and as stated in the DOE
approved written Grantee Quality Control Inspection Policy.
o Grantees will provide a copy of relevant policies and procedures that will
govern the quality control inspection process in accordance with WPN 15-4
Section 3 and outline disciplinary actions for inadequate inspection practices.
This should include a description of how the inspector is related to the work
being done on the home (i.e. did they also audit the home or are they an
independent third-party?) as well as the percentage of homes that will be
included in the Grantee monitoring process.
o Grantees will provide copies of the inspection forms that will be used by
grantee monitors to ensure that work is completed in accordance with the work
quality requirements outlined in WPN 15-4 Section 1.

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V.6

Weatherization Analysis of Effectiveness

An analysis must be provided by the Grantee, per 10 CFR 440.14(c)(6)(i), of the existence
and effectiveness of any weatherization project being carried out by the Subgrantee(s).
This analysis may include analyses that are done on an annual basis but may also include
special analyses that are conducted based on current events. Describe Grantee plans for
analysis of effectiveness activities during this program year and beyond. Examples of
activities DOE would be interested in include the following:
o How the effectiveness of Subgrantee weatherization is assessed?
o How productivity and energy savings between Subgrantees are compared?
o How the comparisons are used in the development of T&TA activities and
priorities?
o How is the training capability being assessed and how is the Grantee
incorporating monitoring feedback?
o What is the Grantee doing to be on a path of continuous improvement?
o How is the Grantee tracking Subgrantee performance reviews?
o If a Subgrantee has failed final inspections, how are things improving?
o If a Subgrantee has management findings or concerns cited as a result of
Grantee monitoring or audit proceedings, how are things improving?
o What are the management mechanisms being put in place this year to affect
improvement?
o Are there technical and financial systems that have been reviewed?
o What has the Grantee done in the area of market analysis to ensure particular
measures are being costed accurately?
V.7 Health and Safety
The final rule, published March 4, 1993, revised the purpose and scope of the Weatherization
Assistance Program to improve the health and safety of low-income persons served by the
Program, especially those that are particularly vulnerable such as the elderly, persons with
disabilities, and children. Health and safety appears in three sections of the regulations 10 CFR
440.16, 440.18 and 440.21. The Health and Safety Plan may be a separate attachment to the
SF-424 in PAGE.
DOE highly recommends in developing the Plan, Grantees use the Health and Safety template
located on the WAPTAC website, http://www.waptac.org/WAP-StandardizedCurricula/Health-0024amp;-Safety-Training-for-Programmatic-Staff.aspx, which is updated
periodically in developing this section. It may be difficult to address all required elements in
the H&S Plan without following the template. In addition to addressing all elements contained
in the table of Weatherization Program Notice 11-6, Grantees should make specific note in this
section any items that are being removed (or conditionally removed) from the Health and
Safety category and instead, meet the definition of Incidental Repair Measures (IRM) in WPN
12-9 and will be charged as IRMs.

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Grantee H&S Plan will also include any other Health and Safety related policies or procedures
including:
o Intake procedures (e.g., capturing pre-existing occupant health conditions).
o Deferral policies due to Health and Safety reasons (e.g., client notification and
list of measures, appeal process, how Grantee refers client to other sources).
o An expression of the H&S cost limit as a percent of the ACPU.
o Details on training plans for H&S issues including continued training on
ASHRAE 62.2-2013.
V.8 Program Management
V.8.1 Overview and Organization
Applicants shall provide a brief description of the Grantee organization that operates the
Weatherization Program. The description shall illustrate how weatherization activities are
structured within the organization, the organization of the Weatherization office (program
managers, monitors, admin, etc.), as well as show the relationship of the weatherization
organization to other units of the state government (e.g., is the agency operating the
Weatherization Assistance Program also responsible for the State Energy Program,
LIHEAP, other housing programs, etc.).
If applicable, applicants may also reference in this section any manuals that are relevant to
the Weatherization Assistance Program operations in this section.
V.8.2 Administrative Expenditure Limits
As 10 CFR 440.18(d) explains, not more than 10% of any grant made to a state may be
used by the Grantee and Subgrantees for administrative purposes -- not more than 5% may
be used by the state, and not less than 5% must be made available to Subgrantees by the
state. However, a state may provide up to an additional 5% to Subgrantees receiving grants
of less than $350,000 of new DOE money. In other words, a state may make available up
to 10% to certain, qualified Subgrantees. In these special cases, a total of up to 15% of the
grant would be allowable for administrative purposes. Should the state elect this option,
applicants must describe the procedures used by the Grantee for approval to provide
additional administrative funds to qualified Subgrantees as specified in 10 CFR 440.18(d).

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Background on Administrative Expenditures
The impact of the 10 percent statutory and regulatory limit on administrative
costs has long been a difficult issue for Subgrantees, particularly small
Subgrantees in the management of their Weatherization programs. It is also a
concern of small Grantees that have been added to the Program in recent years,
and Grantees that have no Subgrantees and are limited to 5 percent on
administrative costs. Beginning with the 1985 Annual Grant Guidance to the
Grantees, DOE identified instances where certain administrative functions
could be charged to the program operations category and encouraged Grantees
to permit their Subgrantees to incorporate these changes. Additionally, the
current regulations include a provision to allow Subgrantees with grants of less
than $350,000 to be permitted to use up to an additional 5 percent of its
subgrant for administrative costs. DOE will continue to rely on the program
guidance documents still in effect since their issuance in their early 1980’s.
The Weatherization authorizing legislation and the Weatherization Program
regulations, 10 CFR Part 440, do not specifically define allowable
administrative costs. DOE expects consistency in the implementation of
program costs, particularly in how the Grantee defines these costs and how
they will be charged to either administration or program operations.
Certain opportunities for flexibility were identified for Grantees and
Subgrantees through Program Guidance. The four separate memoranda
provide the only flexibility on charging administrative costs as issued by
DOE. Copies of these guidance documents can be found on the
WAPTAC website. Included in these memoranda is House Report 98886, which accompanied the 1985 Appropriations Bill and provided
DOE with the original authority to provide relief for Subgrantees on the
issue of administrative costs.
Program Guidance in this area is not mandatory for Grantees. However, the
fact that the flexibility offered in these memoranda would not be
acknowledged by a 2 CFR 200 Subpart F-compliant audit does cause concern
when an independent financial audit of the Program is conducted. An auditor
would note discrepancies in program operations costs that would normally be
charged as traditional administrative costs. DOE will attempt to address this
issue through future training addressing how Grantees can best assure that the
flexibility offered by DOE is understood and applied uniformly.

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V.8.3 Monitoring Activities
Grantees shall follow WPN 16-4 in filling out the monitoring section. This section must be
specific to the current program year monitoring activities.
o Indicate the staff dedicated to the monitoring effort and identify whether they
are technical or administrative monitors. Include credentials of monitors (e.g.,
certifications).
o Grantees must indicate if these staff members are paid for out of the Grantee
administration or T&TA budget category (if T&TA, include the percentage of
funds directed toward this effort). Also include estimates on travel for
monitoring efforts.
o Grantees must ensure that all Subgrantee final inspections, as well as Grantee
technical monitoring, are performed by certified Quality Control Inspectors as
outlined in WPN 15-4 Section 3 and as stated in the DOE approved written
Grantee Quality Control Inspection Policy.
o For the current program year, Grantees must describe and provide their
monitoring schedule in detail indicating not only frequency of visits, but also a
tentative schedule on when these visits may occur.


The plan for Grantee administrative/fiscal monitoring, no less than
annually per each Subgrantee, will describe what the monitoring entails,
potential Subgrantee schedule, and resolution strategy if issues are
identified.



The plan for Grantee technical monitoring of each Subgrantee will
indicate the frequency/number of units to be monitored, whether units in
progress are monitored, the specifics of the monitoring activity (file
review/in unit/etc.), and identify a resolution strategy if issues are
identified and units have already been reported as completed.



Grantees must provide the procedures followed in addressing Subgrantee
corrective actions and the process Grantees follow for the discipline
and/or removal of a Subgrantee from the Program.

V.8.4 Training and Technical Assistance
Applicants shall indicate the methods used to provide training and technical assistance to
Subgrantees, and the methods employed to ensure quality of work and adequate financial
management control at the Subgrantee level. While the overall approach to training,
technical assistance, and monitoring may be constant, budgets and activities may change
from year to year. For this reason, this section must contain a description of the activities to
be undertaken during the program year with funds budgeted for training, technical
assistance, and monitoring on SF-424A under either T&TA or Administrative cost
categories.

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Training and Technical Assistance (T&TA) Activities
T&TA activities are intended to maintain or increase the efficiency, quality and
effectiveness of the Weatherization Program at all levels. Such activities will be designed
to maximize energy savings, minimize production costs, improve program management
and crew/contractor “quality of work,” and/or reduce the potential for waste, fraud, abuse
and mismanagement. The Subgrantees should be the primary recipients of T&TA
activities, although Grantee requirements for monitoring, training support and providing
assistance must also be maintained.
T&TA funds may also be used to train contractors at the Subgrantee level participating in
the Program. In making the determination to pay for contractors’ training, Grantees and
Subgrantees must secure a retention agreement in exchange for the training. The retention
agreement should require that contractors will work in the Program for a specific amount
of time and must align with the cost of the T&TA provided. Examples of contractor/agency
retention agreements can be found on WAPTAC under WPN 10-1 or can be obtained by
request from the Project Officer.
Grantees must ensure that all Tier 1 training paid for with WAP T&TA funds meet the
requirements of WPN 15-4, Section 4.
o Grantees must provide a training plan that provides an analysis of training needs
within the Grantee’s program and a description of how the Grantee will ensure
that all individuals trained with WAP funds will receive regular, comprehensive
training in accordance with WPN 15-4. Please note: this plan can span multiple
program years and it is the Grantee’s decision as to which categories of workers
will be trained and the frequency of that training.
Grantees must describe the proposed training plan and milestones necessary to ensure the
training plan is on pace to be accomplished. At a minimum, the plan must also address the
following elements as part of the submission:
o How does the Grantee training plan reflect feedback from DOE Project Officer
monitoring visits, internal state audits, Grantee field monitoring visits, QA
review visits, IG reports, etc.;
o How is the Grantee maintaining workforce credentials (how are credentials
tracked and how is training being planned and targeted to ensure maintenance
of these credentials?);
o What training will the Grantee provide for Subgrantee staff and whether
attendance is mandatory and the ramifications for non-compliance;
o Whether the Grantee requires any certification or training of Subgrantee staff
prior to hire or by date certain from date of hire;
o How does the Grantee plan reflect industry-wide initiatives and future program
requirements (e.g., certifications, health and safety implementation, etc.);
o How the Grantee compares between Subgrantees the effectiveness and the
energy savings achieved and how these comparisons are used in the
development of T&TA activities and priorities;
o Provide an assessment of the Grantee and the anticipated T&TA activities
necessary to ensure Grantee effectiveness in administering and implementing
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the grant;
o What training activities are planned to execute the Grantee Health and Safety
Plan;
o How does the Grantee approach client education?
V.9 Energy Crisis and Disaster Response Plan
Applicants are encouraged to include energy crisis and disaster plans that have been developed
within their State. By including this in the State Plan process, Grantees are able to free up
resources and respond more quickly in the event of an energy crisis or disaster.
Grantee should review WPN 12-7 to ensure the Grantee is clear DOE does not waive
regulations and the Grantee should demonstrate within this plan an understanding of the
limitations and flexibilities available to the Grantee and Subgrantee network in the use of
Weatherization resources. Grantee should also indicate how an energy crisis or natural disaster
plan is triggered (e.g., federal declaration).
VI. FEDERAL RULES AND REGULATIONS
VI.1 DOE Financial Assistance Rules
Effective December 26, 2014, the DOE Financial Assistance regulations contained in 10 CFR 600
were superseded by the Financial Assistance regulations contained in 2 CFR 200 (with DOE
regulations specific to for-profit organizations codified in 2 CFR 910). WAP formula awards
originally issued for Program Year 2013 will be extended one additional year to Program Year 2016,
and the award Special Terms and Conditions will be updated to require compliance with 2 CFR 200
and 2 CFR 910. DOE requires compliance with 2 CFR 200 and 2 CFR 910 for awards issued after
December 26, 2014.
The Financial Assistance Rules found at 2 CFR 200 and 2 CFR 910 establish uniform policies
and procedures for the award and administration of DOE grants and subgrants. To assist
Grantees, DOE commissioned the development of the “Weatherization Assistance Program
Financial Management Tool Kit” as a universal training curriculum for teaching WAP
professionals how to comply with the financial regulations governing the WAP. The
curriculum provides a detailed explanation of budgetary systems, including a comprehensive
overview of financial management systems, protocols, regulations, and procedures for the
WAP. The tool kit will assist Grantees with providing effective financial management training
to the WAP network. This is a tool, so Grantees are reminded that if questions arise, refer to 2
CFR 200.
VI.2 OMB Cost Principles
Allowability of costs shall be determined in accordance with the cost principles applicable to
the entity incurring the costs. Thus, allowability of costs incurred by State, local or federallyrecognized Indian tribal governments, and non-profits, is determined in accordance with the
provisions of 2 CFR 200 Subpart E, “Cost Principles.”

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Basic Guidelines for Costs
o Costs are allowable if they are necessary and reasonable, not prohibited under
state or local laws, conform to laws and regulations, given consistent treatment,
comply with generally accepted accounting principles, and are not included as a
cost under other Federal programs.
o Allocations of costs must be in proportion to the benefits received, cannot be
shifted to overcome deficiencies in other programs, and must be supported by a
cost allocation plan.
o Applicable credits are to be used to reduce expenditures applicable to a given
grant.
o The total cost of a grant program is comprised of the allowable direct and
allowable indirect costs less applicable credits referenced above.
Indirect Costs
All indirect costs must be negotiated with the cognizant Federal agency. The cognizant
Federal agency is responsible for negotiating and approving indirect cost rates on behalf of
all Federal agencies that award grants and contracts to an organization.
Cost Allocation Plan
Information regarding State/Local-Wide Central Service Cost Allocation Plans are found in
2 CFR 200.416 and 2 CFR 200 Appendix V. Guidelines and illustrations of central service
cost allocation plans are also provided in a brochure published by the Department of Health
and Human Services entitled “A Guide for State and Local Government Agencies: Cost
Principles and Procedures for Establishing Cost Allocation Plans and Indirect Cost Rates
for Grants and Contracts with the Federal Government.”
Allowability of Selected Items of Cost
Below are links to principles to be applied in establishing the allowability of certain items
of cost. These principles apply whether a cost is treated as direct or indirect. Failure to
mention a particular item of cost is not intended to imply that it is unallowable; rather,
determination as to allowability in each case should be based on the treatment or principles
provided for similar or related items of cost.
o 2 CFR 200 Subpart E Cost Principles (State and Local Governments, and
Non-Profit Organizations) – General Provisions for Selected Items of Cost
o Grantees are again reminded, the “Weatherization Assistance Program
Financial Management Tool Kit” provides a number of charts and tools to
assist Grantees in navigating the question of allowability of specific items.
Any potential discrepancies between information contained within this tool
kit and the Code of Federal Regulations shall be resolved in favor of the
Code of Federal Regulations.

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VI.3 Financial Audits
Under the implementation of the OMB Uniform Guidance for Grants, Uniform Audit
Requirements will be effective for non-Federal entity Fiscal Years (FY) which start on or after
December 26, 2014. These audit requirements were found in OMB Circular A-133, “Audits of
States, Local Governments, and Non-Profit Organizations” and have been replaced by Audit
Requirements in 2 CFR Part 200 – Subpart F. Hence, these audit requirements, along with the
new A-133 audit threshold of $750,000, will be in effect on all existing awards as of the
recipient’s new fiscal year.
Grantees must comply with the requirements of 2 CFR 200 Subpart F - Audit Requirements.
The 2 CFR 200 Subpart F audit threshold is $750,000 of annual Federal award expenditures.
All non-Federal entities that expend $750,000 or more in a year in Federal award funds shall
have a single or program- specific audit conducted for that year in accordance with the
provisions of 2 CFR 200. The $750,000 Federal funds threshold includes funds from all
Federal agencies. For purposes of the single-audit, PVE funds are not treated as Federal or
appropriated funds. Subgrantees that spend less than $750,000 are no longer required to have a
single audit. The circular prohibits pass- through entities (Grantees) from charging to Federal
awards the costs of single audits for such recipients. Grantees may not budget for audits of
Subgrantees receiving less than $750,000 of Federal funds. Pass through entities (Grantees) are
held responsible for Federal awards administered by their Subgrantees and will need to review
their overall Subgrantees monitoring process to determine if they need additional monitoring
procedures to ensure Subgrantee compliance.
Entities that expend less than $750,000 a year in Federal awards are exempt from Federal audit
requirements for that year except as noted in 2 CFR 200 Subpart F, but records must be
available for review or audit by appropriate officials of the Federal agency, pass-through
entity, and General Accounting Office (GAO). Grantees that expend more than $50 million a
year in Federal awards will be assigned a cognizant agency. Grantees that expend $50 million
or less will be assigned an oversight agency. Both cognizant and oversight agencies will be
reassigned every 5 years (per 2 CFR 200.513 detailed requirements) and will be the Federal
agency that provides the predominance of Federal funding in the reassignment year.

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