The U.S. Department of Energy’s (DOE) Weatherization Assistance Program (WAP) is directly impacted by the novel COVID-19 pandemic. DOE WAP wishes to uniformly address current issues the WAP network is grappling with as a result of COVID-19. This memorandum contains information on the Impact of COVID-19 on the WAP workforce and clients, and what actions DOE is considering in light of the situation. This information is set forth below in the form of Frequently Asked Questions (FAQs) and DOE’s responses to those questions. DOE will continue to update, as necessary, to address new or ongoing concerns.
Weatherization Program Administration and Production
As access to client homes becomes more limited, what actions will DOE take to address anticipated spending delays related to decreased production of units?
ACTION: DOE will extend grant periods until reasonable analysis demonstrates realistic ability for Grantees, and subsequently Subgrantees, to resume operations and expend funds.
DOE recognizes production will be impacted and encourages Grantees to keep the respective Project Officers (PO) updated on changing situations regarding production.
ACTION: DOE encourages agencies to follow their established, written policies aligned with 2 CFR Part 200 related to use of administrative funds. Administrative funds are not tied to specific production targets by federal rule. However, Grantees may have policies limiting administrative drawn down based on total expenditures. As for labor costs, including salary and fringe benefits, under the Uniform Guidance, agencies can charge the cost of leave to federal grants so long as: (i) the leave is provided under established written leave policies; (ii) the costs are equitably allocated to all related activities; and (iii) the organization uses a consistent accounting basis for costing each type of leave (2 CFR § 200.431(b)).
What options are there for DOE if there is a production decrease, and as a result, the Average Cost Per Unit (ACPU) may be exceeded by Grantees?
ACTION: DOE will allow for both Program Year (PY) 2019 and 2020 funds to be rolled into one budget period that includes the extension of the grant period (6 months to a year). The ACPU (expenditure of financial assistance provided under WAP for labor, weatherization materials, and related matters) cannot exceed $6,500, as adjusted (10 CFR §440.18(a) and (c)). The adjusted annual average for PY 2020 is determined by using the percentage increase in the Consumer Price Index (CPI) or 3 percent, whichever is less. For Fiscal Year (FY) 2020 the ACPU is $7,669. This combination allows all funds within the budget period to function under the greater FY 2020 ACPU number and allows a longer timeframe for work to be done and bring down the ACPU to within allowable amounts, per 10 CFR § 440.18(a) and (c).
Note: This allowance can be extended and combined based on specific conditions of the Grantee.
Where work has been stopped due to client/workforce exposure concerns, will DOE allow flexibility to pay contractors before the final inspection is completed?
ACTION: DOE is unable to waive the requirement for final inspection for reporting completed units to DOE (10 CFR § 440.16(g)). However, Grantees can provide partial payment for allowable activities under the award. For example, a contractor may be paid for in-progress work completed on a home, but has not had a final inspection.
Since 43 July 1 Grantees have not submitted their WAP Annual Plan Application (due 5/1/20), with current CDC social distancing/gathering recommendations, will Grantees still be required to host Hearings prior to submitting the application?
ACTION: Grantees can proceed with virtual public hearings, as long as the provisions within 10 CFR § 440.14 regarding public notice and ability to for public to comment are adhered to (i.e., Webinar, Live Stream, etc.).
Note: DOE encourages Grantees to hold multiple virtual public hearings as some electronic platforms can be overwhelmed. Holding multiple virtual hearings ensures electronic communications are not overwhelmed and allows access to the public for comments and questions.
ACTION: DOE is ready and available to process all State Plan submissions, per normal process and procedures. Awards are being executed in a timely manner to ensure federal funds for WAP are obligated to the Grantees.
When stay at home mandates are lifted, what is the Grantee's responsibility to provide guidance to return to work, aside from providing basic work safe practices, PPE, client agreements for work on homes, etc.?
ACTION: Grantees and Subgrantees should follow guidance issued by state and local jurisdictions when implementing a plan to get back to work, as well as by Federal health agencies such as the CDC and OSHA.
Can local organizations accept verbal signature from clients who do not have the appropriate technology to do electronic signature but are afraid to allow someone into their home?
ACTION: Agencies may accept signatures received via mail or electronically. Clients unable to sign documents electronically online may send a photo of physical signatures via text or email or be provided the option to mail a paper copy of the application with signature.
If a local WAP organization wants to update its technology (e.g. computers, software, video session capabilities), can they charge it to training and technical assistance funds?
In regard to combining the 2019–2020 State Plan, are Grantees required to now have another virtual hearing for the combined plan?
We did not combine program years and due to the extended production pause we now have concerns about ACPU for PY 2020. Can we extend the 2020 grant period beyond March 31, 2021 (for April 1st Grantees) or June 30, 2021 (for July 1st Grantees)?
ACTION: DOE will handle these requests on a case-by-case basis. Grantees should contact their respective Project Officer.
How does DOE suggest Grantees modify health and safety plans in response to COVID-19? Will any changes be made to WPN 17-7?
State and local agencies are developing safety protocols in response to COVID-19 and in preparation for returning to field work. Should safety protocols apply consistently to all households, or can we develop additional protocols for vulnerable households (e.g., elderly, underlying medical conditions)?
ACTION: DOE recommends following thorough safety protocols, as recommended by the CDC and OSHA, with a consistent approach to all households.
Can DOE clarify the types of PPE required for WAP work? At a minimum what is the recommended list of PPE WAP workers should have available? Is the N95 construction-grade mask appropriate for the install crews when they are inside the home? If we are unable to get N95 masks, can we use KN95 masks? CDC makes allowances for alternative PPE. Are these allowable for WAP?
What is the best way to know our state and/or local area's current Phase? The federal 3 phases are different than the 6 phases issued by our Governor. Are we to compare the phases and make the best call if they don't align?
ACTION: Grantees and Subgrantees are encouraged to visit state and/or local websites to obtain and understand requirements in place within their service territory. The Federal Guidelines encourage state and local officials to tailor the application of the Federal criteria and 3 phases to fit local circumstances. Grantees and Subgrantees should utilize guidance issued by state and local jurisdictions when implementing a plan to get back to work, as well as, by Federal health agencies such as the CDC and OSHA. Alignment of state and local guidance to the federal guidance is not required.
Does DOE have recommendations for disinfection methods?
ACTION: Grantees and Subgrantees should clean and disinfect the workplace consistent with CDC guidance on Cleaning and Disinfecting Your Facility and Reopening Guidance for Cleaning and Disinfecting Public Spaces, Workplaces, Businesses, Schools, and Homes. While the CDC’s guidance is not a requirement, following these recommendations will help reassure your employees that it is safe to come back to work, as well as help protect your CAA from liability for claims of exposure to COVID-19 in your facilities.
ACTION: Grantees and Subgrantees should continue to follow protocol as outlined in the Grantee’s Health and Safety Plan approved by DOE, which per WPN 17-7, Weatherization Health and Safety Guidance, require Grantees to outline a “Process for verifying safe work practices (e.g., EPA’s Renovation, Repair and Paint [RRP] Program for lead-safe work, Occupational Safety and Health Administration [OSHA] standards, DOE’s Standard Work Specifications [SWS], building codes). Grantees must develop a process that periodically monitors in-progress work or describe another method used to ensure safe work practices are being followed. Results of the monitoring must be made available to DOE upon request.” Modifications need not be made to plans unless a budget amendment is required.
Please clarify allowable funding for additional cleaning, disinfection, and PPE required as a result of COVID-19.
ACTION: As per 10 CFR 440.18(d), Allowable Expenditures, costs related to materials needed to safely perform weatherization work can be charged to either Program Operations or Health & Safety. The current Health & Safety Guidance, WPN 17-7, includes a section for worker safety. PPE can logically be charged to either Program Operations or Health & Safety budgets, but this determination should be made at the Grantee level and should be applied consistently across the service territory and across all jobs. In the event, during a grant period, it is determined that approved H&S budgets will be insufficient, the Grantee must submit a request for a higher limit to their Project Officer.
Aside from performing weatherization work where N95 masks are required for worker safety (e.g. installing insulation), what other face coverings can weatherization staff entering a home wear specific to reducing the risk of spreading COVID-19?
ACTION: As stated in Weatherization Memorandum 062: Weatherization Assistance Program's Response to Guidelines for Opening Up America Again - Phase One & Frequently Asked Questions (FAQs), DOE recommends organizations follow the guidance set forth by FEMA on use of PPE for non-healthcare workers. https://www.fema.gov/fact-sheet/addressing-ppe-needs-non-healthcare-setting. The following link provides detailed information on the efficacy of available masks https://www.cdc.gov/niosh/npptl/respirators/testing/NonNIOSHresults.html.
ACTION: DOE reminds Grantees and Subgrantees to continue following applicable OSHA standards, WPN 17-7, and training for proper use of PPE during weatherization work.
How do you enforce requirements with contractors, including adding new language to contracts, pricing new requirements, and ensuring requirements are met?
ACTION: Grantees are reminded that work should conform to the approved State Plan. In addition, Grantees and Subgrantees are responsible for ensuring the work completed conforms to Program rules and contractual agreements, including the purpose for the products and services and support for the estimated costs.
Can Employers screen employees for COVID-19, and what are the related human resources protocols? Can we use DOE funds to pay for testing employees for COVID (any testing cost and their time)?
ACTION: Grantees and Subgrantees should refer to the U.S. Equal Employment Opportunity Commission (EEOC) guidance on screening employees for COVID-19.
Additional information specific to Community Action Agencies and local agencies can be referenced through the Community Action Program Legal Action, Inc. (CAPLAW) website.
Weatherization Workforce and Clients
What recommendations are in place related to interaction and exposure that may put workforce and/or clients (specifically vulnerable clients in high risk categories) at added risk for contracting COVID-19?
ACTION: DOE encourages Grantees to utilize their authority to suspend all weatherization services, or severely limit weatherization services, to service areas impacted by COVID-19 while also ensuring safe practices are being implemented.
Note: Clients may refuse services at this time due to COVID-19 concerns, however Grantees and Subgrantees should ensure that these clients can be given priority once the COVID-19 crisis has passed.
ACTION: DOE encourages the workforce to increase their knowledge on safe practices through educational efforts, including utilization of CDC-issued resources and information exchange with Grantee-level State Board of Health contacts, including social distancing, covering coughs (and refraining from work if they show signs/symptoms of illness), washing hands frequently, and confirming homes being visited are illness-free prior to visit. DOE encourages the workforce to monitor CDC-issued resources and information frequently to stay apprised of new recommendations and guidelines that may be promulgated as a better understanding of COVID-19 is reached.
ACTION: DOE will extend flexibility to Grantees in meeting on-site monitoring requirements since the Grantee operations are also impacted by inability to visit homes. Grantees concerned about meeting the monitoring requirements of the grant should forward those concerns to the respective DOE PO.
Can weatherization labor/workforce and resources (e.g., trucks) be used to support community relief efforts (e.g., food delivery, assisting in foodbanks, cleaning schools, etc.)?
ACTION: DOE does not have a mechanism to support (with labor or resources) community emergency responses. DOE will advise Grantees of any changes to this concern.
Increased Focus on Certification and Training
What will happen with Home Energy Professional Certifications that expire over the next six months and without opportunity for renewal, leaving the WAP workforce without certified Energy Auditors and Quality Control Inspectors (QCI)?
ACTION: DOE is actively working with the Building Performance Institute (BPI) to extend expiring certifications until reasonable analysis demonstrates realistic ability for Grantees and Subgrantees to resume recertification.
What opportunities are there for completing training requirements outlined in Weatherization Program Notice (WPN) 15-4?
ACTION: DOE will work with the Weatherization Network to encourage any required staff training to be held online or live stream if they can no longer be held in person.
ACTION: DOE encourages Grantees and Subgrantees to use this time on administrative and training and technical assistance activities (T&TA), including, but not limited to, completing inventory reconciliation, updating policy and procedures manuals to ensure compliance with federal rules, and considering development of a deferral policy and tracking tool.
ACTION: DOE encourages Grantees and Subgrantees to update and/or develop safety protocols to use when the programs are able to move to full production.
ACTION: DOE encourages online trainings, virtual conferences, and live/recorded webinars to serve as interim training tools and opportunities for the WAP.
ACTION: DOE will work with the Weatherization network to promote available resources and rethink the logistics of previously planned onsite training and conferences (e.g., BPI Online Courses, WAP Administrative Trainings, Weatherization Standardized Curricula, Weatherization Financial Management Toolkit, WAP Grantee Manager Training Toolkit, etc.).
What options are there for reimbursing costs already incurred by agencies for cancelled trainings/events (e.g., airline cancellations, hotel non-refundable rooms, etc.)?
ACTION: DOE encourages agencies to follow their written, approved policies on this matter.
Does DOE have recommendations for conducting virtual audits during phase 2, and moving forward
ACTION: While some tools such as GIS systems, satellite imagery (e.g., Google Earth) and 3D modeling tools (e.g., Google Sketchup) may allow for fairly detailed energy models to be constructed from the exterior of the building, they cannot replace the details collected using onsite diagnostic tools such as blower doors, combustion analyzers, and infrared cameras; nor replace the detailed health and safety inspections required to ensure the building is safely weatherized. If Grantees wish to use some form of “virtual” audit to temporarily supplement their energy audit practices, they must submit a detailed process to DOE for approval. The process must address how any “virtual’ assumptions are to be made and how these assumptions will be field verified prior to work commencing on the home as well as how the appropriate safety inspections will be conducted in order to avoid unnecessary expenditures on homes that need to be deferred. DOE views “virtual” audits as another “tool in the box” that can reduce time spent in the field, but one that needs clear direction and adequate verification to be effective and safe.
Has DOE changed the policy on blower doors related to the risk of spreading the virus?
ACTION: DOE’s policy on blower door testing has not changed. Any organizations ceasing to conduct blower door testing must have a well-formulated and written policy for determining how to enter and verify air sealing measures. Contact your DOE Project Officer for approval.
Examples of how Grantees and Subgrantees are handling blower door concerns at this time include:
- Donning complete PPE according to Grantee guidelines and conducting blower door testing as usual, being careful to remain out of the direct path of airflow.
- Distribute face coverings to everyone on site (residents and workers) and/or bring everyone out of the home for the duration of testing. Initially open all interior doors and all or several windows in the dwelling and run the blower door (pressurization or depressurization) for a few minutes. Air can then flow from multiple directions and purge the air from the whole dwelling. After purging the air, put the dwelling into standard blower door testing mode and proceed with diagnostic testing, being careful to stay out of the direct path of air flow throughout the entire procedure.
- Use historical blower door test data from previous weatherization jobs to run an energy audit and determine the air leakage factors and air leakage reduction percentages. Using those data points, along with the actual square footage of the home, generate a CFM50 air leakage input number for the audit and a projected post-weatherization CFM50 number.
The National Association for State Community Services Program (NASCSP) is collecting safe work protocols developed by Grantees. https://nascsp.org/coronavirus-resources/nascsp-resources-on-covid/
ACTION: Consider the following prior to conducting a blower door test:
- Invite/ask clients step outside if able to do so.
- Emphasize the importance of weatherization crew and clients to wear a mask.
- Seek input from DOE Project Officer on best practices.
- Consider implications for ASHRAE ventilation requirements, described below.
If blower door test are not conducted, how will Subgrantees conform to ASHRAE 62.2 ventilation requirements?
ACTION: If a Grantee chooses to temporarily discontinue the use of the blower door, the calculation of the ASHRAE ventilation requirement will not include an infiltration credit (ASHRAE 62.2-2016; Section 4.1.2), similar to when calculating the ventilation requirement for new homes. The alternative compliance method can still be used, but without an infiltration credit, will likely result in higher ventilation rates.
ACTION: Subject to approval by the DOE Project Officer, if a Grantee is using historical data in a method approved by DOE to predict pre- and post-weatherization air leakage rates, the predicted post-weatherization air leakage rates can be used as a typical blower door test result would be used to calculate the infiltration credit.
Is measure skipping allowable in relation to COVID-19 safety concerns?
ACTION: Per Weatherization Program Notice 19-4, Revised Energy Audit Approval Procedures, Related Audit and Material Approvals, issued by DOE on January 17, 2019, “Energy audits are required to use interactive procedures to determine the most cost-effective measures and to prioritize these energy saving measures by SIR. Once approved, all prioritized weatherization measures modeled in the audit that meet the SIR requirement must be installed in the dwelling unit. Deviating from the audit prioritized list of modeled measures conflicts with the intent of the rules. A more detailed discussion of measure skipping is in Attachment 8 of this Guidance.”
Through unemployment, with federal stimulus funds, individuals are receiving an additional $600 per week along with their regular unemployment benefit. Do these funds count an income or are they exclusive?
The government distributed stimulus checks to income qualified households. Are the funds counted as income or are they exclusive?
What relief (if any) can we give for Weatherization Program Notice 20-3, Poverty Income Guidelines and Definition of Income on “Self-Certification: After all other avenues of documenting income eligibility are exhausted, self-certification is allowable. However, evidence of the various attempts at proving eligibility must be contained in the client file, including a notarized statement signed by the potential applicant indicating that the applicant has no other proof of income.”
ACTION: During this time of sheltering-at-home, WAP agencies could allow a client to self certify that they have no other proof of income but specify that a notarized statement later will be required, once the jurisdiction is in Phase 3 of the Guidelines.
WAP organizations have data-sharing agreements with other federal programs for eligibility purposes (e.g., LIHEAP, SNAP). Would it be appropriate to share any available COVID-19 data among programs?
What are DOE’s recommendations for resuming service to vulnerable households?
ACTION: Per WAP Memorandum 060: Weatherization Assistance Program Frequently Asked Questions Related to COVID-19 clients may refuse services at this time due to COVID-19 concerns, however Grantees and Subgrantees should ensure that these clients can be given priority once the State or local jurisdiction is implementing Phase Three of the Guidelines.
Please clarify whether or not the additional $600 in Unemployment Benefit counts as income? Others programs, including LIHEAP do not consider it income.
ACTION: As stated in WAP Memo 062: Weatherization Assistance Program's Response to Guidelines for Opening Up America Again - Phase One & Frequently Asked Questions (FAQs), DOE recommends reviewing Weatherization Program Notice 20-3, Poverty Income Guidelines and Definition of Income. Unemployment benefits are included in the definition of income. Specifically, the Definition of Income states Cash Receipts include “Regular payments from social security, railroad retirement, unemployment compensation, strike benefits from union funds, worker's compensation, veteran's payments, training stipends, alimony, and military family allotments.” Further, DOE recommends Grantees and Subgrantees revisit the Categorical Exclusions stated in Section C of the Definition of Income.
LIHEAP already has a new Declaration of Income (self-declaration that does not need to be notarized), will we be able to use this for Weatherization rather than having to get customers to present two separate self-declaration of income?
ACTION: As stated in WAP Memorandum 062: Weatherization Assistance Program's Response to Guidelines for Opening Up America Again - Phase One & Frequently Asked Questions (FAQs), “During this time, WAP agencies could allow a client to self-certify that they have no other proof of income but specify that a notarized statement later will be required, once the jurisdiction is in Phase 3 of the Guidelines.”
Applicant Selection and Preparation
What types of COVID-19 data will be publicly available? Will any of this help us screen buildings?
ACTION: Refer to state and local health agency resources for additional information. DOE does not receive specific data related specific buildings.
Deferral process & tracking is needed for clients that are not able to be served immediately due to COVID-19 illness. Can WAP organizations ask for proof that home has been properly sterilized/cleaned following COVID-19 illness?
- Clean AND disinfect frequently touched surfaces daily. This includes tables, doorknobs, light switches, countertops, handles, desks, phones, keyboards, toilets, faucets, and sinks.
- If surfaces are dirty, clean them. Use detergent or soap and water prior to disinfection.
- Use a household disinfectant as a final step.
What are reasonable deferral timeframes for homes with a household that has a positive COVID case, exposure to a positive COVID case, and/or COVID-like symptoms?
Is there one standard client application for DOE WAP?
Monitoring and Inspection Protocol
Does the Grantee technical monitoring staff need to conduct site visits in order to fulfill monitoring requirements?
ACTION: Per WPN 20-4, DOE PO teams will have regular communications with Grantees and conduct desktop and ad hoc monitoring. As part of both desktop and ad hoc monitoring, the PO team will use reference materials (PAGE, production reports, conversations, correspondence, policies and procedures, fiscal reports, and Quality Assurance (QA) contractor data) to assist in this activity. Specifically,
- Requires quarterly reviews driven by Grantee Financial and Production reports submitted on the 30th of the month following the end of the quarter.
- Verifies the Grantee is in compliance with program requirements or identifies needed corrective actions to become compliant.
- If deficiencies are identified, monitoring assessments can be issued and may require CAPs within 30 days of issuance.
ACTION: Grantee responsibility during technical monitoring continues to be ensuring that the right work is being done correctly in the homes served and that the Program is running as intended. DOE maintains that site visits are the simplest way to fulfill this responsibility, but understands that some areas may wish to minimize the number of visits to a client’s home. Grantees may propose a temporary alternative to technical site visits and conduct monitoring in that way upon approval from their DOE Project Officer.
ACTION: Grantees should modify existing monitoring protocols to ensure they can safely work in Subgrantee offices and client homes to evaluate the local agency’s safety protocols and client satisfaction. Consider scheduling all monitoring to occur once the State has entered Phase Three.
Do Subgrantee Quality Control Inspectors (QCI) still need to conduct final inspections of completed units
ACTION: As stated in WAP Memorandum 060: Weatherization Assistance Program Frequently Asked Questions Related to COVID-19, DOE is unable to waive the requirement for final inspection for reporting completed units to DOE (10 CFR 440.16(g)). However, Grantees can provide partial payment for allowable activities under the award. For example, a contractor may be paid for in-progress work completed on a home that has not yet had a final inspection.
If we are performing final inspections while clients are not home, what are acceptable ways to obtain customer signature for completion of work?
ACTION: In units where final inspections are complete, Grantees are advised to work with Subgrantees to develop a safe signature collection process—collecting signatures by mail and/or electronically (clients unable to sign documents electronically online may send photo signatures via USPS mail, text or email), when physical signatures cannot be obtained.
Does DOE have recommendations for how Grantees should modify their monitoring protocols to ensure they can safely work in local agency offices and client homes?
ACTION: Grantees should follow the guidelines issued by Federal, State, and local jurisdictions as they related to worker safety in offices and homes.
How should an organization respond if contacted by a recent WAP client and notified a household member has become ill?
What responsibility does a WAP organization have to follow-up with clients if an employee or contractor tests positive for COVID following weatherization work?
Subgrantees should to refer to the Grantee and the Community Action Legal Services, Inc. (CAPLAW) website for responses to the following questions:
How do we require/enforce clients to disclose household health statuses?
How would programs determine the severity of an underlying health concern to decide whether it was a health hazard that should be deferred or not?
ACTION: Grantees and Subgrantees should refer to the CDC’s “People Who Are at Higher Risk for Severe Illness” list.
ACTION: Please refer to Building Readiness: Reopening Our Doors.
How can we ask screening questions to determine if the client/household has "at risk" or "high risk" people while maintaining client privacy?
ACTION: Per WPN 17-7, Weatherization Health and Safety Guidance, Table of Issues, Occupant Pre-existing or Potential Health Conditions, Subgrantees are required to screen occupants to review known or suspected health concerns. Subgrantees should create a screening tool to use with ALL clients (to ensure there is no discrimination) prior to entering a client’s home to perform weatherization or other activities. Per Weatherization Memorandum 062: Weatherization Assistance Program's Response to Guidelines for Opening Up America Again - Phase One & Frequently Asked Questions (FAQs), the screening tool could include questions like:
- Has anyone in the household tested positive or are presumed positive for COVID-19? If so, have they met the CDC criteria to be around others per the section “When it’s safe to be around others: ending home isolation?”
- Has anyone in your household experienced fever, cough or shortness of breath in the last two weeks?
- Has anyone in your household been in contact with someone who has had a fever, cough or shortness of breath in the last two weeks?
- Does anyone in the household have underlying medical conditions or are they in frequent contact with someone who has underlying medical conditions?
ACTION: Please refer to the CAPLAW document, Building Readiness: Reopening Our Doors.
Can we ask clients to leave their homes while work crews are in their homes alone?
ACTION: Clients may be asked to leave their homes; however, they cannot be required to leave. Consider alternatives to asking a client to leave (e.g. provide PPE to client, contain client to one room/space, relocate client to the home of a friend/family member, waitlist unit until conditions are safe to resume weatherization work.) Regarding related questions received about liability of workers being in homes without residents present, service providers should already have policies governing appropriate actions if problems arise after workers are alone or unsupervised in the client homes. These same policies can be applied in the current situation.
If you have questions regarding the information in this Memorandum, please contact your DOE Project Officer.