Noted: Manny Teodoro, a public policy scholar at the University of Wisconsin, suggests that states should prioritize simplicity over precision — by using an allocation formula based on population and poverty. He argues in favor of a two-tier system. Large utilities, which generally have more experience with financial assistance programs and more administrative resources, should be capable of handling outreach and distribution on their own. Smaller utilities, which have less sophisticated billing systems and fewer staff, should be assisted by regional social services agencies.
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