Affordable and Safe Energy Program for Low-Income Households in Minnesota

1. FFY2012 EAP Annual Training Section 2 Includes Chapter 1 Control Environment, Chapter 3 Service Provider Responsibility, Chapter 3 Energy Vendor and PUC

2. Chapter 1 Program Control Environment

3. Business Strategy Model Intentions • Maintain affordable, continuous, and safe home energy for low-income Minnesota households

4. Values • Overall: • Affordable, safe, and dependable energy • Advocacy • Good stewardship of resources • Being realistic about limitations • Quality • Partners and Partnerships (see Coordinated Responsibility Model) • Understanding the program in the context of broader public policy and other needs of low-income Minnesotans • Being the compass but not the map • Reward positive, proactive behavior by all energy stakeholders • Regarding Households: • Dignity and privacy • Participation (see Coordinated Responsibility Model) • Empower people to make informed decisions regarding their energy use and needs • Serving the most in need – balancing total number of participants, makeup of participants, and levels of service • Regarding Collaboration: • The responsibility to provide a safety net • Working towards the same goals • Stakeholders personal commitment and accountability • Represent our own personal perspective, the views of our stakeholder group, and the world from multiple perspectives • Actively coordinate across programs and departments • Regarding Policy Direction: • Creative and flexible approaches • Consistency • Balance of simplicity and fairness • Recommendations based on a sound community analysis • More strategic than operational • Timely and proactive in order to mitigate emerging problems

5. Means • Offerings (Products & Services) • Energy bill payment • Furnace repair or replacement • Energy related crisis intervention • Advocacy • Outreach • Referral • Information • Education • Conservation Coordination and Collaboration • Demonstrate effectiveness of investment • Markets (Customers) • Households, emphasizing low-income: • Families with children under age five • Families with members who are disabled • Seniors • EAP Director and Staff • Local Service Providers • Policy decision makers • Funders (e.g. HHS) • Energy Vendors • Mechanical Contractors • PAC members • Weatherization Assistance Program • Partner organizations • Community • Tax payers • Utility rate payers

6. The Minnesota Model • EAP employs a “Coordinated Responsibility Model” • The Model assumes households, vendors, and the program all have a role in assuring heat for low-income households during the winter. • Program responsibility includes providing heating payment supplements, case management and advocacy for households, and maintaining influence with vendors. • Energy Vendor responsibility is to be as flexible as possible so energy payments leverage the highest possible level of service to the household. • Household responsibility is to make reasonable and planned payments for energy service, access government aid when necessary and communicate with vendors and government service providers.

7. Internal Controls • Recent Developments include • Annual Office of Legislative Auditors report • No Findings for the program side of LIHEAP • DOC has recently hired an Internal Controls Director • Nationally, Minnesota is represented on the Program Integrity Workgroup. This workgroup is developing internal control in a number of areas • We continuing to incorporate internal controls in all areas of EAP especially in the area of energy vendors

8. Bill Grant Deputy Commissioner Minnesota Department of Commerce Division of Energy Resources

9. Q & A Coordinator’s Role

10. Chapter 2: Overview of Service Provider Responsibility

11. Chapter Structure • Control Environment • Risk Assessment • Control Activities • Communication and Information • Monitoring

12. Changes in Chapter 2 • Monitoring and self monitoring • Vendor Monitoring • Appeals • Inventory and Purchase Requests and documentation • Web Page • Conflict of Interest

13. Chapter 3 – Energy Vendors

14. Chapter 3 – Training Topics • Context • Vendor SME group • Policies and Procedures • Chapter Changes • Agreement Between EV and SP Changes • Vendor Communication • Vendor Monitoring Effort • Issues Management

15. Chapter 3 - Context Continued emphasis on increasing internal controls: • General Accounting Office (GAO) • Office of the Legislative Auditor (OLA) • National Program Integrity Workgroup • Main focus on energy vendor transactions occurring at the Service Provider, state office, and energy vendor company office • Energy vendor monitoring plays a key role

16. Vendor Subject Matter Expert Group Creation of the Vendor SME • Need for Service Provider experts providing energy vendor knowledge and advice to State Office • Representation Considerations: • Small and large SPs (based on # of HH served) • All types of fuel vendors • Geographically diverse • Volunteers • EACA Chair Recommendations

17. Vendor SME Members • Pam Wild, MVAC • Sue Thompson, SEMCAC • Phil Wold, Tri-Valley • Rachel Bagley, Western Community Action • Fenton Hyacinthe, CA of Mpls • Scott Zemke, CAPSH • Catherine Fair, CAPRWC • Joan Markon, Fond du Lac • Mary Heilman, AEOA

18. Vendor SME Effort Definition Effort Definition: Work Completed: • Vendor chapter and agreement review • EACA recommended improvements

19. Vendor SME – Your Voice Going Forward: • The Vendor SME represents all members of EACA on vendor issues • This group is available to you – make your voice heard • Vendor Monitoring Improvements • Vendor Registration Improvements • TBD

20. Chapter 3 – New Language Consumption Data Specifications (Page 2) • New language to provide clarity on what is considered true consumption • Examples added for guidance • Situations when complete consumption is not available • Also located in Chapter 5

21. Chapter 3 – New Language Assignment of Payments (Page 3) New language provides clarification to vendors about 30% electric and reiterates responsibility to appropriately apply payments: Page 3: Households may elect through their EAP application to have 30% of their primary heat benefit paid to their non-heating electric energy account. This option exists because non-heat electricity is most often crucial to operating a heating unit.

22. Chapter 3 – New Language Continued The vendor is responsible for applying EAP payments correctly for heat and non-heat electric payments. If the 30% option has been selected by the Service Provider on behalf of the household, the electric vendor must apply 30% of a benefit to the non-heating electric account. If the vendor provides multiple utility services, including both heating and electric non-heating energy, and their billing system does not allow for separation of the two, they must notify their EAP Service Provider of their method to assure payments are correctly applied. Disconnections should not occur as a result of a vendor failing to appropriately apply EAP payments.

23. Chapter 3 – New Language Early Notification of Payment & Emergencies (Page 5) • Vendors must supply EAP Service Providers with a 24 hour emergency contact number to address after hours emergencies. This requirement enables Service Providers to comply with LIHEAP Law, Section 2604(c) requiring EAP to provide some form of assistance within 18 hours after an eligible household in a life-threatening situation applies for crisis benefits.

24. Chapter 3 – New Language Vendor Registration and Change of Vendor Information (Page 6) • A complete IRS W-9 Form has been added to the vendor registration information list • Also can be found as a link on EAP Tools on the web in the Vendor Management Forms Section

25. Chapter 3 – Edit & eHEAT Enhancement Vendor Monitoring & Reporting Requirements (Page 7) • Vendors must contact the Service Provider if for any reason the consumption amount needs to be changed after original submission. • The word “should” was changed to the word “must”. • eHEAT enhancement: Energy Vendors are locked out of consumption fields after eligibility has been determined.

26. EV/SP Agreement Changes Section I. The vendor and the Service Provider will: • Added #11 Work together to ensure EAP payments are appropriately applied to accounts and used for EAP services as designated by the Service Provider.

27. EV/SP Agreement Changes Section II. The Service Provider will: • Added tank setting to #3 Make authorization through eHEAT, telephone, fax or electronic communication for: • Payments for electricity, heating fuels and delivery of fuel. • Continuation or reconnection of connected utilities. • Payments for service deposits, pressure tests, line bleeding, tank setting, tank rental, membership fee, if applicable. • Removal from load limiters. • Payments due and past due amounts for electricity and heating fuels.

28. EV/SP Agreement Changes Section III. The vendor will: • Edited #3, #5, #14 3. Provide to the Service Provider a written price list for normal and customary services for home energy costs eligible for payment with EAP funds,including but not limited to: Leak seek, etc. 5. Provide at the request of the customer, the Service Provider or the State, information on applicant households’ home energy costs, consumption data for a twelve month period which includes the previous heating season,delivery dates, bill payment history or arrearage history. This information will be provided in the format requested.

29. Section III Edits Continued 14. Continue service, reconnect or deliver fuel to households eligible for EAP crisis payments or as negotiated by the Service Provider on behalf of the household.

30. EV/SP Agreement Changes Section V: Edited Signature Block

31. Vendor Communications • Primary Relationship between SP and EV • Escalating communication • eHEAT Vendor Manual • EAP Tools on the web • Refund Help Sheet • Continue to encourage use of eHEAT

32. Vendor Monitoring Effort • Monitor 5% of vendors including a variety of fuel providers (Chapter 2 and 3) • Have a monitoring schedule so all vendors are monitored overtime • Problematic vendors require more timely monitoring • Encourage in person, on site monitoring • The monitor hat v. trainer hat • Monitoring is an opportunity to discuss issues and approach before the start of the program • Use the path to a solution when planning monitoring visits (revisit Jeff’s 2010 Training PowerPoint)

33. Group Monitoring Effort • History • Effort Definition • Plan • SME assist in developing an approach • Execute approach • Evaluate outcome • Pilot • Shutdown Effect

34. Vendor Issue Management Examples of current issues being worked on: • MERC not counting taxes and fees in consumption • Xcel PAR not having access to correct consumption • Muni Payment Issues • GAP as it relates to EAP • Program vendor internal controls

35. Energy Assistance Program Fall Training August 10-11, 2011 Public Utilities Commission Tracy Smetana Stay Warm Minnesota

36. Public Utilities Commission • Who is the Public Utilities Commission? • What is the Cold Weather Rule? • How can Energy Assistance providers assist customers with Cold Weather Rule protection? • What other utility consumer assistance is available?

37. Public Utilities Commission • Regulate • Local and in-state long distance telephone companies • Investor-owned electric and natural gas utilities • Permitting for power plants, pipelines, transmission lines • 5 Commissioners • Appointed by the Governor • Serve staggered terms • FT employment • 40 staff

38. Public Utilities Commission • Services provided by the PUC Consumer Affairs Office • Mediation between utility companies and their customers • Consumer Education • Telephone Discount Programs • Cold Weather Rule • Utility Resource • Public Comments

39. Public Utilities Commission • Interagency Relationships • Attorney General • Department of Commerce • Federal Communications Commission • Governor • Legislators (State and Federal) • Public Utilities Commissions in other states • Social Service Organizations

40. Cold Weather Rule • Protects customers from having heat shut off in the winter. • Residential • Heat affected • Electric and natural gas • October 15 through April 15

41. Cold Weather Rule • Regulated Cold Weather Rule (CWR) Companies • Alliant Energy/Interstate Power & Light • CenterPoint Energy • Community Utility Company • Dakota Electric Association • Great Plains Natural Gas • Greater Minnesota Gas • Island Gas/Sheehan’s Gas Company • Minnesota Energy Resources Corp (MERC) • Minnesota Power • Northwest Natural Gas • Northwest Natural Gas of Murray County • Northwestern Wisconsin Electric • Otter Tail Power • Xcel Energy

42. Cold Weather Rule Pre-season bill inserts • Explanation of the Cold Weather Rule • Explanation of no-cost and low-cost methods to reduce energy consumption • Third-party notice • Ways to avoid disconnection • Information regarding payment agreements • Explanation of the customer's right to appeal • List of names and telephone numbers for county and local energy assistance and weatherization providers in each county served by the utility

43. Cold Weather Rule CWR Payment Plan • Reconnect service OR prevent disconnection. • Available to all residential customers, regardless of income. • Payment installments need not be equal; may be based on factors such as lump sum payments or additional income expected during payment period. • If income at or below 50% of state median, payments no more than 10% of household income.

44. Cold Weather Rule • Disconnect notice • Ten working days prior to disconnection date • CWR insert must be included • What’s next?

45. Cold Weather Rule • Customer contacts utility • NO written application required • Household income at/below 50% of state median income • Enter into mutually acceptable CWR payment plan • Consider household’s financial resources and circumstances • No more than 10% of household income • Make and keep CWR payment plan • Customer must contact utility to request modification of CWR payment plan • Payment agreement ends April 15 unless utility and customer agree to a different end date

46. Cold Weather Rule • Customer contacts utility • NO written application required • Household income greater than 50% of state median income • Enter into mutually acceptable CWR payment plan • Consider household’s financial and other extenuating circumstances • Make and keep CWR payment plan • Customer must contact utility to request modification of CWR payment plan • Payment agreement ends April 15 unless utility and customer agree to a different end date

47. Cold Weather Rule • Customer contacts utility • Utility and customer do NOT agree on a CWR payment plan • Utility informs customer of right to appeal • Utility sends appeal form to customer • Customer has 10 working days to complete appeal and send to PUC • PUC has 20 working days to issue decision on appeal

48. Cold Weather Rule • Customer contacts utility • Customer fails to keep CWR payment plan • Customer subject to disconnection

49. Cold Weather Rule • Customer does not contact utility • Must investigate whether occupied or vacant • If vacant, proceed with disconnection • If occupied… • Make contact with customer • Offer CWR payment plan • Customer subject to disconnection without CWR payment plan

50. Cold Weather Rule • Income Verification • Customer who receives low income assistance does not need to provide additional verification • Proof of income = pay stubs, tax return, Social Security statement, etc • Self declaration • Customer has right to appeal utility’s determination