4 best practices for Solar for All recipients: Avoid common pitfalls

To avoid common pitfalls – while maximizing benefits – Solar for All funding recipients should consider these “lessons learned” from other federal programs.

Recipients of federal Solar for All (SFA) funding have a unique opportunity to bring clean, renewable energy to more than 900,000 households in low-income and disadvantaged communities throughout the U.S. This $7 billion investment – part of the Greenhouse Gas Reduction Fund (GGRF) – is designed to enable state, nonprofit, and Tribal organizations to expand equitable access to solar power and energy storage.

In order to quickly follow through on these commitments, recipients must understand how to roll out a high-performing and compliant program.

As with previous federal programs such as the Homeowner Assistance Fund (HAF), Emergency Rental Assistance Program (ERAP), and State and Local Fiscal Recovery Funds (SLFRF), implementation of SFA presents a range of challenges. Based on our experience supporting participants in those programs, potential obstacles for SFA participants include complex application processes (leading to lower participation rates, especially in historically underserved communities), insufficient internal coordination among key stakeholders (creating inefficiencies), and inadequate reporting mechanisms (making it difficult to monitor program health), to name a few.

To avoid these and other pitfalls – while maximizing program benefits – recipients of Solar for All funding should consider these best practices: “Lessons learned” from what we’ve seen in other federal programs.

1. Optimize internal communication and coordination to avoid delays.

When administering a program such as SFA, there tends to be a significant focus on external outreach and communication. While it is important that the target population is aware of how to apply and comply, it’s internal communication among stakeholders – including key players such as administrators, finance staff, internal auditors, and vendors – that can make or break these large-scale programs.

This is especially true for entities that are newer to allocating hundreds of millions of dollars in funds and may need to rely on services from the private sector. Without a good internal structure that keeps members of the organization and key stakeholders on the same page at all times, a program is more susceptible to breaking down. Inconsistent communication and lack of internal coordination can lead to inefficiencies, duplication of efforts, and delays in service delivery. Something as simple as awaiting an attorney’s signoff, for example, can hold up program administrators from implementing a necessary policy adjustment. Thus, key decision-makers need to be engaged early and often.

From the initial phases of the SFA program onward, it’s critical to establish clear communication channels and regular check-ins to stay aligned and on task. Recipients should develop a detailed rollout plan that outlines roles, responsibilities, and timelines for all stakeholders. Additionally, consider using technology solutions, like ticketing systems to manage and track requests, to streamline administrative processes and improve efficiency.

2. Enhance administrative capacity to better manage the workload.

In the case of new federally funded programs such as HAF, ERAP, and SLFRF, organizations frequently faced difficulties in managing the increased administrative workload, which includes staying compliant with federal requirements, deploying funds in a timely fashion, and maintaining sufficient staff.

To effectively execute SFA and avoid overwhelm, recipients must invest in building administrative capacity. This includes hiring qualified staff and working with vendors who are adept at administering, monitoring, and overseeing large-scale and novel programs. An experienced program administrator is invaluable. Upskilling existing staff and internal stakeholders is another worthwhile step, so that more team members have the needed training if staffing challenges arise.

3. Optimize the application process, and protect against fraud.

Two must-haves for SFA programs are a well-designed application and clearly defined documentation requirements. Many ERAP, HAF, and SLFRF hopefuls faced intricate application processes and stringent documentation requirements.

These programs face a catch-22:

  • The more complex the process is, the slower it is (as each application takes longer to fill out and review), and the harder it is for people to participate.
  • And yet an overly simple application process opens the door to professional fraudsters who use sophisticated methods to apply for grant programs and steal funds. For example, they may use synthetic identities to create people that appear real on paper but aren’t, then flood a program with fraudulent applications.

The answer isn’t to complicate the application, but to implement anti-fraud measures at the outset. For example, a machine learning model can work in the background to detect patterns across applications, spotting trends and commonalities in, say, 10,000 applications at the same time; it could detect similarities in the metadata or in the applicant’s IP address, at which point trained team members can make informed decisions about the applications’ legitimacy.

Two additional keys to a well-designed application:

  • Make sure that each section has clear instructions. This improves the program experience for applicants and leads to a smoother application process.
  • Use closed-ended questions, which not only are easier for applicants to answer, but also provide structured data that can be easily analyzed. Structured data is necessary to develop insightful reporting.

4. Plan early on for robust reporting and compliance.

Recipients of Solar for All funds must fulfill numerous data and reporting requirements. Thus, all involved team members must stay up to date on compliance details.

Recipients are ultimately responsible for making sure that subrecipients comply with the terms and conditions of the Solar for All award, so it’s important to establish efficient and reliable reporting systems early in the program; it’s not enough to put requirements in the grant terms and conditions and expect subrecipients to comply. For example, if a recipient subawards funds to a local nonprofit to help deliver a SFA program and that nonprofit doesn’t comply with the rules and regulations, EPA could take note of the noncompliance and require the recipient to return funding. The recipient would either have to recoup funding from the nonprofit or go into its own coffers.

Keep in mind also that federal reporting requirements may change midstream. Therefore, a compliance team should be set up to regularly review and update reporting procedures as necessary. Here, automated systems can assist with timely and accurate reporting – though any system-generated reports need to be human-assessed for accuracy.

In conclusion

Federal assistance programs such as HAF, ERAP, SLFRF, and now Solar for All (under the umbrella of GGRF) were designed to serve a common goal of supporting vulnerable populations and enhancing community resilience in the face of economic and environmental challenges. All of them were new programs, and thus experienced a steep learning curve.

Unlike the aforementioned programs, GGRF will involve many entities that are less experienced in administering federal programs at this scale. So it is critical that all recipients, not only new awardees, follow recommended best practices. Improved internal coordination, enhanced administrative capacity, an optimized application process, and detailed reporting will help position Solar for All recipients to overcome potential challenges, so they can focus on advancing environmental justice in the communities that need it most.

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Roman Castillo

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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.