Workshop #7 Review of the CARE program Joint Utility Presentation

1. Workshop #7 Review of the CARE program Joint Utility Presentation

2. CARE Enrollment and Penetration Estimates

3. 2011 September YTD Enrollment Stats

4. PY 2012 - 2014 CARE Estimated Participation

5. Are there indications that show that ineligible households may be enrolled in the CARE Program?

6. Recertification and Post Enrollment VerificationHistory & Process

7. Recertification History • D. 89-07-062 approved a 3-year recertification cycle for individually metered customer and annually for tenants of submetered facilities • D. 94-12-049 shortened the recertification cycle to 2-years for individually metered customer and retained a 1-year cycle for tenants of submetered facilities, non-profit group living facilities and agricultural housing • D.05-12-026 approved recertification process improvements pilots: • Recertification via telephone enrollment • Use of a probability model to extend the recertification period from two years to four years • D.06-12-038 authorized: • Four-year recertification process for low-income customers on a fixed income • Continuation of pilot of four-year recertification for customers passing a probability model • Recertification of CARE eligibility using Interactive Voice Recognition (IVR) system • Internet- based CARE enrollment and recertification • D.08-11-031 authorized: • Consistent renewal processes for tenants of submetered facilities (2-year and 4-year for fixed income tenants) • Two-Year renewal for non-profit group living facilities, agricultural housing • Approval to continue recertification pilots using probability model & IVR on an ongoing basis

8. PG&E Recertification Process PG&E Recertification Process • Current Process: Customers self-recertify their household’s eligibility via paper • application, online application, or Automated Voice Messaging • Every two years for active participants • Every four years for those determined to have fixed income* • Recertification Timeline: • 120 days prior to expiration of benefits: Automated “Recertification for Enrollment” calls to all impacted customers - continued monthly until recertified or removed • 90 days prior to expiration of benefits: Recertification Application mailed (if no response to prior phone call) • 45 days prior to expiration of benefits: Reminder letter sent • If no response to above notices: Removal – invitation is sent to re-apply for CARE benefits if they still qualify • *those customers noting pension, social security, SSP or SSDI, Medicaid/Medi-Cal (age 65 and over) or SSI as their income source

9. PG&E Post Enrollment Verification Process Criteria used to select customers enrolled or recertified during the previous month includes, but is not limited to: Previous ineligibility for CARE Previous removal due to non-response to PEV Reported ineligibility Discrepancies in application • Enrollment source • Usage levels and • Random selection • Reports of fraud • Current PEV Timeline: • Letter mailed to selected customers • 15 days after date of letter: Reminder phone call to customers • 45 days after date of letter: Non-respondents removed • Letter sent alerting impacted customers of removal • Removed customer can be reinstated without losing discount if within the same billing cycle

10. SCE Recertification Process PG&E Recertification Process • CARE customers are required to recertify their program eligibility every two years. • Four years if on fixed-income • Customers are notified of recertification in the language in which they initially enrolled in the program. • Multiple letters and IVR alerts are used to notify customers. • Customers are able to recertify via the web, IVR, and by mail. • Customers have up to 90 days to respond to initial recertification request. • Program recertifications are shared with The Gas Company, similar to program enrollments.

11. SCE Post Enrollment Verification Process PG&E Recertification Process • Currently, 1% of SCE CARE customers are required to verify their program eligibility each month. • All customers have a probability of being selected with higher-use customers having greater probability of selection. • Customers are notified of the verification request in the language in which they initially enrolled in the program. • Multiple letters and IVR alerts are used to notify customers. • Customers have up to 90 days to respond to verification requests. • SCE seeks to data share verifications with The Gas Company, similar to the existing practice of data sharing program enrollments and recertifications.

12. SDG&E Recertification Process • Customers self-recertify their household’s eligibility via paper application, online application, or outbound and inbound Auto Voice Messaging • Customers are required to recertify every two years except: • Every four years for customers determined to have fixed incomes • Customers can be exempted once by passing a probability model • Customers are recertified through leveraging prior to the recertification date • Recertification Timeline: • 120 days prior to expiration of benefits a courtesy renewal call is made • 90 days prior to expiration of benefits a recertification application is mailed (if no response to prior phone call) • 45 days prior to expiration of benefits a second reminder letter is sent • 30 days final CARE bill has a notice warning of pending removal • Once removed, the customer can be reinstated within the same billing cycle without losing the discount • *Those customers noting pension, social security, SSP or SSDI, Medicaid/Medi-Cal (age 65 and over) or SSI as their income source

13. SDG&E Post Enrollment Verification Process • CARE customers are randomly selected to provide proof of CARE eligibility • Once selected, a probability models is used to determine the likelihood of eligibility • The model, developed by an outside consulting firm, estimates the likelihood of CARE eligibility based on median neighborhood income, max usage summer months, home ownership and dwelling type • CARE customers are also income verified for a variety of reasons, including: • Previous ineligibility for CARE • Previous removal due to non-response to PEV • Calls or letters regarding customers on CARE from a neighbor or employee • Customers who submit multiple applications with significant discrepancies • Customers who have several open accounts • CARE Verification Timeline • 90-days prior to removal date 1st request mailed • 45-days prior to removal • A bill message notifying the customer that they will be removed appears on the final CARE bill prior to removal • Once removed, the customer can be reinstated within the same billing cycle without losing the discount

14. SoCalGas Recertification Process • Customers self-recertify their household’s eligibility via paper application, online application, or outbound and inbound Auto Voice Messaging • Customers are required to recertify every two years except: • Every four years for customers determined to have fixed incomes • Customers can be exempted once by passing a probability model • Customers are recertified through leveraging prior to the recertification date • Recertification Timeline: • 30 days prior to recertification date a courtesy renewal call is made (available in English and Spanish). • On the recertification date, a bilingual recertification application is mailed (if no response to prior phone call) in English and one of other four languages. Customers have 90 days to respond. • 45-days after recertification application is mailed, a bill message reminds customer to respond to the request. • 100 days after recertification is mailed, non-responsive customers are removed from CARE

15. SoCalGas Post Enrollment Verification Process • CARE customers are randomly selected to provide proof of CARE eligibility • Once selected, a customer’s likelihood of eligibility is evaluated using a probability model. • The model developed by an outside consulting firm estimates the likelihood of CARE eligibility based on median neighborhood income, max usage in the winter months, and dwelling type. • CARE customers are also income verified for: • Prior non-response to PEV • Tip-off calls from neighbors of CARE customers • Recommendation by SoCalGas’ internal departments, such as Billing, Field and Collections • Application is questionable • CARE Verification Timeline • Randomly selected customers who do not pass the probability model are mailed bilingual PEV requests in English and one of four other languages. Customers have 90 days to respond • 45-days after PEV mailed date, a bill message notifies the customer that SoCalGas has not yet received his application and documentation. • For non-response within 100 days, customers are removed from CARE and re-billed from the PEV mailed date.

16. Overview of Proposed Changes Program

17. PG&E 2012-2014 CARE Proposals • Implementation of participation requirements to address CARE households with extremely high energy usage levels. • Broaden local support for enrolling potential CARE customers by further utilizing Community Outreach Contractors (COC). • Expand in-language communications to households. • Recommendation that the Commission revisit the categorical programs accepted for automatic eligibility for CARE.

18. SCE 2012-2014 IOUs CARE Proposals • Authorization to allow call center representatives to enroll customers on CARE over the phone using SCE’s web-based application. • Increase annual post enrollment income verification from 1% to 5% of participating customers. • Propose to require customers who do not pass income verification to increase the wait from one-year to two-years before they can re-enroll by self-certifying their income. • Internal file sharing with ESAP/EAF to share program verifications. • Allow customers the ability to select their communication preference for future program communications. • New Capitation Program name change to CARE Community Enrollment Program. • Continue Outreach & Marketing best practices.

19. SDG&E CARE 2012-2014 Proposals PG&E Recertification Process • Continuation of outreach and enrollment efforts previously implemented, such as direct mail, automated phone campaigns, email blast, and door-to-door enrollment • Expanded focus to reach hard-to-reach including the disabled, Limited English Proficient, and senior customer communities • Leverage existing systems to implement recertification and income verification requests through email • Implementation of scanning technology that will enable better tracking of a customer’s enrollment status • Implement data sharing with water utilities per D. 11-05-020

20. SoCalGas 2012-2014 CARE Proposals • Outreach with focus on hard-to-reach including the disabled, Limited English Proficient, and senior customer communities • Continue best practices of current application processing • Optimize communication options by utilizing outbound dialing and email to prior to mailing : • Recertification and verification request • Confirmations for approved enrollments, recertification and PEV customers • Remind customer of required actions before benefit expires • Promote paperless avenues and implement paperless archiving • In addition to the current PEV process, request verification of customers least likely to be CARE eligible.  • Collect additional information from sub-metered tenants for more effective outreach • Implement data sharing with water utilities

21. Categorical Eligibility and Categorical Enrollment Proposals

22. Regulatory History • D. 89-07-062 established the CARE program (formerly the Low Income Ratepayer Assistance Program) authorized PG&E to utilize the California Department of Economic Opportunity (DEO) to certify applicants for its program. • The Commission also recognized the concept of “categorical eligibility” used by DEO to qualify its HEAP program applicants which permitted clients to qualify by virtue of being eligible for public benefits programs (Aid to Families with Dependent Children (AFDC), Supplemental Security Income/State Supplemental Payment (SSI/SSP); Veterans’ and Survivors Pension Benefits, or Food Stamps or by otherwise demonstrating a total household income within HEAP’s income guidelines. • Rulemaking (R.) 94-12-001 - Addressed whether the current income-based criteria for LIRA and the Universal Lifeline Telephone Service program should be changed.

23. D. 99-07-016 • Defined categorical eligibility as “qualifying for LIRA based on a customer’s participation in other public assistance programs such as Aid to Families with Dependent Children (AFDC) • Rejected categorical eligibility for the programs because it would be too costly to implement and might result in customers with incomes in excess of the eligibility criteria for LIRA and the ULTS programs being admitted into the programs. • D. 01-05-033 Applications Requesting Approval of 2001 Low Income Programs • Declined to adopt a categorical eligibility procedure stating the Commission was unwilling to waive the eligibility requirements for CARE without consideration of the reasons for the differences in eligibility requirements and income documentation among the various programs and the cost implications of making the change • Determined that categorical eligibility can result in many customers participating in CARE or LIEE who are not income eligible unless the eligibility requirements and income documentation requirements are made identical among the programs

24. Automatic Enrollment D. 02-07-033 • Adopted an Automatic Enrollment Process for CARE in order to assist in the attainment of the Commission’s goal “to reach 100% of low income customers who are eligible and desire to be enrolled in the CARE Program.” • Directed the IOUs to automatically enroll participants in the following “partner agency” programs in CARE: • Medi-Cal and Women, Infants and Children (WIC) programs administered through the California Department of Health Services. • Healthy Families program administered by the Managed Risk Medical Insurance Board • Energy Assistance Programs administered by the California Department of Community Services and Development • Established a data sharing process where the Commission would serve as a clearinghouse to identify electronic matches between agency and utility customer records to ensure confidentiality of client information provided by the partner agencies. • Due to the partner agencies concerns with Federal Privacy Laws, the automatic enrollment process envisioned by the Commission was unsuccessful.

25. IOU’s Categorical Enrollment Program 2007 – 2008 Program Applications • Requested authorization to implement a categorical enrollment process as an alternative to the Commission’s Automatic Enrollment process • If approved, the IOUs would work together to review the eligibility requirements and income documentation requirements of several public assistance programs and determine which most closely aligned with the CARE eligibility requirement. • The objective of the IOUs proposals was to make it easier for customers to apply for CARE and LIEE and to help achieve the Commission’s 100% penetration goal • The IOUs’ proposal was approved in D. 06-12-038

26. Definition of Income • When determining income eligibility, CARE assesses total household income. For purposes of the program income eligibility, income is defined as: • GO 156 Section 2.1.52. (effective May 3, 2007) - “all revenues, from all household members, from whatever source derived, whether taxable or non-taxable, including, but not limited to: wages, salaries, interest, dividends, spousal support and child support, grants, gifts, allowances, stipends, public assistance payments, social security and pensions, rental income, income from self-employment and cash payments from other sources, and all employment-related, non-cash income.” • D.99-07-016, the Commission determined that household income includes “income derived from such assets, such as interest and dividend, and income derived from the gain from their sale.” • D.99-07-016, at Ordering Paragraph (“OP”) 3. In the same decision, the Commission determined that household income excludes “liquid assets,” “borrowed monies, or [] monies transferred from one checking, savings, or similar account to another account.”

27. CARE and CE Programs Eligibility Criteria Differences • CARE’s income requirement is based on gross income from all sources of all persons living in the household and income must be at or below 200% of Federal Poverty Guidelines • All CE programs’ eligibility criteria do not appear to align with CARE • None consider the income of all people living in the household • Each program defines income differently • LIHEAP and Healthy Families A&B could exceed 200% of FPL • LIHEAP: based on 75% of state median income • Healthy Families A&B: at 200-250% FPL • Several programs allow exemptions for certain types of income • Detailed comparisons attached

28. IOU’s 2012-2014 Program Proposals for Categorical Eligibility PG&E Recertification Process • The IOUs are requesting, and support, CPUC conducted workshops to determine all public assistance programs currently under categorical eligibility that have income requirements consistent with CARE income requirements. • PG&E and SoCalGas propose to decline a customer’s participation in CARE if application indicates CE program participation and total household income exceeds CARE income guidelines. • SDG&E is proposing that customers who apply for CARE via CE also self-certify that their household income meets CARE income guidelines. • PG&E, SDG&E, and SoCalGas plan to require income documentation for PEV Process.