California's Mobilehome Residency Law requires operators of manufactured housing communities to pass through CARE and FERA utility discounts to eligible residents. This is not discretionary — Cal. Civ. Code § 798.43.1(c) mandates that the full discount be applied at 100% of the utility's published discount rate. No portion may be retained by management.
For operators, CARE and FERA compliance involves more than just applying a discount to a bill. It requires annual resident notification, enrollment tracking, accurate discount calculation, and appropriate handling of sensitive income-related data. Getting any piece wrong — the notice, the percentage, the application — creates compliance exposure.
This guide covers what CARE and FERA are, what the law requires of operators, how discounts should appear on bills, and the most common mistakes to avoid. For context on how these obligations fit into the broader regulatory picture, see the complete compliance guide.
What Are CARE and FERA?
CARE and FERA are California Public Utilities Commission (CPUC) programs that provide discounted utility rates to qualifying low-income households. Both programs exist because energy costs represent a disproportionate share of household expenses for low-income Californians, and the state has determined that rate relief is appropriate.
CARE — California Alternate Rates for Energy
CARE provides a discount on both electric and gas service. The discount is typically 20% on electric and 20% on gas, though the exact percentage varies by utility and rate schedule. Eligibility is based on total household income at or below 200% of the federal poverty guidelines. Residents may also qualify through participation in certain public assistance programs, including:
- CalWORKs (California Work Opportunity and Responsibility to Kids)
- CalFresh / SNAP (Supplemental Nutrition Assistance Program)
- Medi-Cal
- Supplemental Security Income (SSI)
- Federal public housing assistance or Section 8 Housing Choice Vouchers
- Head Start income-eligible programs (different from enrollment-based)
- National School Lunch Program (NSLP)
- Women, Infants, and Children (WIC) program
CARE enrollment is verified by the serving utility and requires periodic recertification (typically every two years, though this varies by utility).
FERA — Family Electric Rate Assistance
FERA provides a discount on electric service only — there is no FERA equivalent for gas. The discount is typically 18% on electric service. FERA is available to households of three or more persons with total household income between 200% and 250% of the federal poverty guidelines. Because the income threshold is higher than CARE, FERA serves as a bridge program for families who earn too much to qualify for CARE but still face significant energy cost burdens.
A key distinction: FERA does not accept categorical eligibility through public assistance programs. Qualification is based solely on household size and income.
The Operator's Legal Obligations
Cal. Civ. Code § 798.43.1 establishes several specific obligations for operators of manufactured housing communities with respect to CARE and FERA. These obligations apply to all master-metered communities — compliance is not optional.
Annual Notice
Operators must provide written notice to all residents at least once per year informing them of the availability of CARE and FERA programs. The notice must include eligibility criteria and information on how to apply. The purpose is to ensure that eligible residents are aware of the programs — the operator cannot assume that residents already know about CARE and FERA or that they will seek the information independently.
Application Assistance
Operators must make CARE and FERA applications available to residents and provide reasonable assistance with the application process upon request. This means maintaining current application forms and being prepared to help residents complete them. It does not require the operator to determine eligibility — that is the utility's function.
100% Discount Passthrough
When a resident is enrolled in CARE or FERA, the full discount must be passed through on their utility bill. The operator cannot retain any portion of the discount for administrative costs, billing overhead, or any other purpose. The discount percentage applied must match the utility's published CARE or FERA discount for the applicable rate schedule.
Accurate Calculation
The discount must be calculated on the correct base amount using the correct percentage. CARE and FERA discounts are typically applied to the energy charges on the bill (usage-based charges), though the specific application varies by utility and rate schedule. Applying the discount to the wrong component of the bill — for example, calculating it on the total bill including non-discountable charges — may result in an incorrect passthrough amount.
How Discount Passthrough Works on a Bill
The following example illustrates how a CARE discount should appear on a resident's electric bill in a master-metered community served by a utility with a 20% CARE discount.
Correctly Applied CARE Discount
Consider a resident with 487 kWh of electric consumption in a billing period, billed under a tiered rate schedule:
- Tier 1 (baseline): 350 kWh × $0.26/kWh = $91.00
- Tier 2 (above baseline): 137 kWh × $0.37/kWh = $50.69
- Base service charge: $0.79/day × 30 days = $23.70
- Subtotal before discount: $165.39
- CARE discount (20%): −$33.08
- Total after CARE discount: $132.31
The bill should show each component: the tiered usage charges, the base service charge, the CARE discount as a separate clearly labeled line item, and the net total. This makes the discount transparent and verifiable.
Incorrectly Applied CARE Discount
Common errors in CARE discount application include:
- Wrong percentage: Applying a 15% discount instead of the utility's published 20% CARE rate — the resident receives a discount, but not the full amount they are entitled to.
- Missing discount: The resident is CARE-enrolled but the bill shows no discount at all — the operator failed to track enrollment status or the billing system does not support CARE processing.
- Hidden discount: The discount is applied but not shown as a separate line item — the bill shows only the net charge, making it impossible for the resident to verify that the correct discount was applied.
- Stale rate: The utility updated its CARE discount percentage but the operator is still applying the old percentage — both the amount and the compliance are wrong.
Common Mistakes
Based on the requirements of Cal. Civ. Code § 798.43.1 and the practical realities of operating a manufactured housing community, these are the most frequently encountered CARE/FERA compliance failures.
Failing to Provide Annual Notice
The annual notice requirement is easy to overlook, especially for operators managing multiple properties. But it is a standalone obligation — even if an operator correctly passes through discounts for enrolled residents, failing to provide annual notice means eligible residents who are not yet enrolled never learn about the programs. The operator is non-compliant with the notice requirement regardless of how well they handle active enrollments.
Not Tracking Enrollment Status
Operators who do not maintain current CARE and FERA enrollment records cannot reliably apply discounts. Enrollment status changes — new residents may be eligible, existing enrollments may lapse, recertification may be required. Without active tracking, discounts are missed or applied to the wrong accounts.
Retaining Part of the Discount
Some operators apply a partial discount — passing through, for example, 15% instead of the utility's published 20% CARE rate — and retain the difference. This violates Cal. Civ. Code § 798.43.1(c) regardless of the reason. The statute requires 100% passthrough. There is no administrative fee exception.
Not Updating Discount Rates
When the utility updates its CARE or FERA discount percentages — which can happen when new tariff schedules take effect — operators must update their billing accordingly. Continuing to apply a previous discount rate after the utility has published a new one is a passthrough violation, even if the operator was compliant under the old rate.
Confusing CARE and FERA
CARE and FERA have different discount percentages, different eligibility criteria, and different utility coverage (FERA is electric only). Applying a CARE discount to a FERA-enrolled resident — or vice versa — results in an incorrect passthrough amount. Billing systems must distinguish between the two programs.
The Sensitivity of CARE/FERA Data
CARE and FERA enrollment is inherently sensitive because it indicates that a resident's household meets income-based eligibility criteria. A resident enrolled in CARE has a household income at or below 200% of the federal poverty level. A resident enrolled in FERA has a household income between 200% and 250% of the federal poverty level. This is financial information that residents reasonably expect to remain private.
Privacy Obligations
Operators should handle CARE and FERA enrollment data with heightened confidentiality:
- Enrollment status should not be disclosed to other residents, community staff who do not handle billing, or any third party without a legitimate billing-related need to know.
- Physical and digital records containing CARE/FERA enrollment information should be stored securely and accessible only to authorized billing personnel.
- If billing is handled by a third-party agent, the agent should maintain the same level of confidentiality for enrollment data.
- Bills showing CARE or FERA discounts should be delivered securely — not posted publicly or delivered in a manner that reveals enrollment status to other residents.
While the MRL does not include a dedicated CARE/FERA privacy provision, general privacy principles and the sensitive nature of income-related data make this a prudent practice. Mishandling enrollment data could create additional liability exposure beyond the billing compliance requirements themselves. For a broader view of compliance obligations including all 8 MRL billing rules, see our detailed rule-by-rule breakdown.