1. August 15 & 16, 2012 FFY2013 EAP Annual Training FFY2013 EAP Annual Training Part 3: Xcel Energy; Energy Vendors; Public Utilities Commission; Internal Controls; Documentation, Program Eligibility

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24. August 15 & 16, 2012 FFY2013 EAP Annual Training 24 Q&A Xcel Energy

25. August 15 & 16, 2012 FFY2013 EAP Annual Training 25 Chapter 3 Energy Vendors

26. August 15 & 16, 2012 FFY2013 EAP Annual Training 26 Training Highlights  Context  New chapter content  Increasing EV knowledge  Increasing EV responsibility  Energy vendor training  Energy vendor monitoring  Reminders and areas for improvement Chapter 3 Energy Vendors

27. August 15 & 16, 2012 FFY2013 EAP Annual Training 27 Context for Improvements  Significant improvements this year  “The Finding”  Crisis JAD  National Program Integrity Working Group Final Report  Revision process engaged:  Vendor SMEs (Thank you)  PUC  The big 4 energy vendors - Xcel, CPE, MERC, MN Power  DOC attorneys Chapter 3 Context

28. August 15 & 16, 2012 FFY2013 EAP Annual Training 28 Increasing EV knowledge of program  Primary Heat and Crisis  Program benefit description  Eligibility requirements  Allowable costs  Crisis information verification required of energy vendors  Broken down by type of vendor  Specifies information SPs will ask  Specifies post delivery verification for delivered fuels  Instructions to reduce ineligible Crisis deliveries  Delivered fuel vendors Chapter 3 New Content

29. August 15 & 16, 2012 FFY2013 EAP Annual Training 29 Increasing EV abilities  Instructions for searching eHEAT for payments  Resources for payment questions  Instructions for entering refunds in eHEAT Chapter 3 New Content

30. August 15 & 16, 2012 FFY2013 EAP Annual Training 30  Coordinated Responsibility Model  Accuracy, effectiveness, efficiency and integrity of services  Role in internal controls  Consumption, account information and benefit delivery  Conduct control measures  Before applying payments to account  Post payment as well  Some lack ability – need to work towards it  Implement and maintain eHEAT security policies  More improvements coming Chapter 3 Active Participation

31. August 15 & 16, 2012 FFY2013 EAP Annual Training 31 Control measures:  Account credits: Crisis payments do not create a credit on an account  Account for an unoccupied dwelling: Payments are applied only to active accounts at occupied dwellings  Household refund requests: Requests are reviewed for potential noncompliance issues first and are only granted after September 30  Households that have moved: Refund EAP within 10 days of a move  Questionable payments: Payments are questioned if they appear abnormal to EAP practices  Two EAP households’ payments to one account: Only one EAP household’s payments are applied to one account Chapter 3 Active Participation

32. August 15 & 16, 2012 FFY2013 EAP Annual Training 32 Changes to the Agreement  “Dwelling” language added throughout  Cable, internet, telephone added to unallowable expenses  eHEAT security requirements FFY13 signed agreements must be received before distributing payments Chapter 3 SP/EV Agreement

33. August 15 & 16, 2012 FFY2013 EAP Annual Training 33 Roles DOC  Big 4 (76% of FFY12 EAP HHs)  Associations  Plans to develop training tools Service Providers  Assure all energy vendors understand program services, requirements, policies, and procedures  Invest time now – decrease issues later Chapter 3 EV Training

34. August 15 & 16, 2012 FFY2013 EAP Annual Training 34  Project Planning  Coordinated effort  Improvements to the Monitoring Report  Great job this year – many issues discovered  Issues identified should be reported to the DOC  T&TA (Training & Technical Assistance) opportunity  Year round activity  Thank you! Chapter 3 EV Monitoring

35. August 15 & 16, 2012 FFY2013 EAP Annual Training 35 Q&A Energy Vendors

36. Energy Assistance Program Fall Training August 15-16, 2012 Public Utilities Commission Brian Swanson 36

37.  Who is the Public Utilities Commission?  What is the Cold Weather Rule?  How can Energy Assistance providers assist customers with Cold Weather Rule protection? 37

38.  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

39.  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

40.  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

41.  Protects customers from having heat shut off in the winter  Residential  Heat affected  Electric and natural gas  October 15 through April 15 41

42.  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

43. 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

44. 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

45.  Disconnect notice  Ten working days prior to disconnection date  CWR insert must be included  What’s next? 45

46.  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

47.  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

48.  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

49.  Customer contacts utility  Customer fails to keep CWR payment plan ▪ Customer subject to disconnection 49

50.  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

51.  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 51

52.  No deposit or late fees if household income at or below 50% of state median income AND keeping CWR payment plan  No disconnection during any appeal process  Timely payment = within 7 calendar days 52

53.  Cooperative/Municipal CWR  Written application required  Applies only to households at/below 50% of state median income  No 10% cap on payment  Appeal process does not include PUC  Requires notice to Energy Assistance provider before disconnecting unoccupied residential unit  Reconnection provision added 2007-2008 season 53

54.  Keys to protection  Contact utility company  Payment plan based on customer’s financial situation  Make and keep a payment plan  PUC available to answer questions, assist customers 54

55.  When something doesn’t seem right  Best scenario is to have the household call PUC directly so we can get all of the information  The Service Provider can also call if household is unable to  Provide as much specific information as possible  There may be others with the same issue 55

56.  Medical equipment in use  Requires electricity  Necessary to sustain life  Written certification from a medical doctor  The customer must enter into a payment agreement  Applies to all electric utilities  Statute is silent on re-certification 56

57.  No disconnection if National Weather Service issues… Excessive heat watch Heat advisory Excessive heat warning  Applies to all electric utilities 57

58.  Department of Commerce www.commerce.state.mn.us www.commerce.state.mn.us  Division of Energy Resources www.energy.mn.gov  Office of the Attorney General www.ag.state.mn.us www.ag.state.mn.us  Stay Warm Minnesota www.staywarm.mn.gov www.staywarm.mn.gov 58

59. Brian Swanson Consumer Mediator Minnesota Public Utilities Commission 121 Seventh Place East Suite 350 St Paul MN 55101-2147 651-296-0406, option 1 1-800-657-3782, option 1 Fax 651-297-7073 consumer.puc@state.mn.us PublicComments.puc@state.mn.us www.puc.state.mn.us 59

60. August 15 & 16, 2012 FFY2013 EAP Annual Training 60 Q&A PUC

61. August 15 & 16, 2012 FFY2013 EAP Annual Training 61 Internal Controls

62. August 15 & 16, 2012 FFY2013 EAP Annual Training 62  Start of Internal Controls  Potential OLA finding in 2008  Developing internal controls since then  While undertaking each new effort, internal controls framework is at the core of our business  Need to further develop internal controls  State and national efforts are also driving internal controls Internal Controls

63. August 15 & 16, 2012 FFY2013 EAP Annual Training 63 Documentation

64. August 15 & 16, 2012 FFY2013 EAP Annual Training 64 Intention To enable sound documentation practices By  Explaining why documentation is an essential business practice  Developing understanding of the reasons to document Context  John started this presented at EACA  EAP has talked documentation in ICF context for years  Many SPs have strong practices Documentation (IC)

65. August 15 & 16, 2012 FFY2013 EAP Annual Training 65 Why Documentation Training?  DOC is commonly asked about documentation  SPs ask:  When do I document?  What is required?  It’s important to understand the principles and guidance of making documentation decisions Documentation (IC)

66. August 15 & 16, 2012 FFY2013 EAP Annual Training 66 Documentation is:  A general business practice  Applied to business processes to enable transaction and accountability  Essential to ensure integrity Documentation (IC)

67. August 15 & 16, 2012 FFY2013 EAP Annual Training 67 Why  A means of communication & transparency  When applications or household data need to be shared  Or used at a later date  A means of quality control  Accurate documentation enables checks on processes  The documentation must be understandable and complete  A means of program integrity & accountability  Makes processes auditable  Used when incidents happen to validate and verify actions Documentation (IC)

68. August 15 & 16, 2012 FFY2013 EAP Annual Training Documentation What to Document

69. August 15 & 16, 2012 FFY2013 EAP Annual Training 69 What to Document Document key interactions:  Changes  Verifications  Transactions  Approvals  Unusual situations within the business process Documentation (IC)

70. August 15 & 16, 2012 FFY2013 EAP Annual Training 70 What is it? What is it?  WWWWH Documentation (IC) Notes: 10/17/12 Phone Call to Fred Smith at GasCo - confirmed $326 arrearage amount – Disconnection date 11/1/12 - JM  Who – Fred, JM  What – Confirmed $326 Arrearage, Disconnect Date  When – 10/17/12  Where - GasCo  How – Phone call

71. August 15 & 16, 2012 FFY2013 EAP Annual Training 71 What is it? Any physical docs when possible  Email pasted into notes field  Copy in file and note referring to it  Electronic version saved Documentation (IC) 10/17/12 From: Fred Smith (GasCo) Sent: Wednesday, Oct. 17, 2012 1:14 PM To: SP App processor Subject: HH # 11111111 Confirmed $326 arrearage amount – Disconnection date was 10/2/12 10/17/12 Printed portal in HH file - Confirmed emergency info - JM Notes:

72. August 15 & 16, 2012 FFY2013 EAP Annual Training 72 Considerations  This is a general practice  Anything that affects your decision making  Just because the manual doesn’t say it is not an explanation  Don’t need it until you need it  Few routine interactions may seem routine  Then later issues arise and you cannot recreate the situation  This can be true normal activities & incidents  Get good at it as a discipline Documentation (IC)

73. August 15 & 16, 2012 FFY2013 EAP Annual Training 73 Best Practices  Develop common documentation methodology for your agency  Train staff on:  WWWWH  Being specific  Critical thinking  Do quality control checks and adjustments  Integrate it into your processes, don’t look at it as extra work  Accept it as a necessary part of the business--protects the HH, you, your SP, program Documentation (IC)

74. August 15 & 16, 2012 FFY2013 EAP Annual Training 74 Chapter 5-Program Eligibility

75. August 15 & 16, 2012 FFY2013 EAP Annual Training 75 Highlights Household Definition  Nursing home or other institution Income Types Not Counted for EAP  Capital gains (1040 Line 13)  Child support  Lump Sums  MSA Chapter 5 Program Eligibility

76. August 15 & 16, 2012 FFY2013 EAP Annual Training 76 Highlights Income documentation for self employed  Most current federal tax return Households With Inadequate Income  Review manual language  Worksheet Expedited Verification  Eliminated Chapter 5 Program Eligibility

77. August 15 & 16, 2012 FFY2013 EAP Annual Training 77 Household Moves to a Nursing Home or Other Institution, Including Jail or Prison  If a household moves permanently to a nursing home or other institution, the new residence does not qualify for EAP benefits  If only one member of a household moves permanently to the institution, the remaining household member(s) continue to be served according to their most recent notification letter Chapter 5 Program Eligibility

78. August 15 & 16, 2012 FFY2013 EAP Annual Training 78 Household Moves to a Nursing Home or Other Institution, Including Jail or Prison  A person is temporarily in a nursing home or other institution as long as there is an expectation he or she will be moving back home within the current program year  If there is no such expectation, consider the move to be permanent  If a household member is permanently living in a nursing home or other institution at the time of application:  Exclude this person as a household member  Exclude this person’s income Chapter 5 Program Eligibility

79. August 15 & 16, 2012 FFY2013 EAP Annual Training 79 Household Moves to a Nursing Home or Other Institution, Including Jail or Prison  When a household moves permanently to a nursing home or other institution:  Request a refund of remaining funds from the energy vendor  Deobligate the refunded amount  Contact the household and tell them their current residence does not qualify for EAP assistance and their remaining benefit has been refunded to their Service Provider Chapter 5 Program Eligibility

80. August 15 & 16, 2012 FFY2013 EAP Annual Training 80 Income Types NOT Counted for EAP Capital gains (1040 Line 13)  Do not count anything on Line 13  Worksheet -- Appendix 5B Child support  Same as FFY12  Matches WAP  Household may be required to complete Inadequate Income Worksheet Chapter 5 Program Eligibility

81. August 15 & 16, 2012 FFY2013 EAP Annual Training 81 Income Types NOT Counted for EAP Lump sums  Clarified  Do not include one-time lump sum RSDI, SSI, SSDI, and Death Benefit Social Security payments as income  Do not include one-time lump sum Veteran’s benefit payments as income MSA  Do not count any MSA payments Chapter 5 Program Eligibility

82. August 15 & 16, 2012 FFY2013 EAP Annual Training 82 Self Employed - Income Documentation Change  The most recent Federal Tax Form 1040 the household has completed  If it includes 12 months of self employment income  If HH was self employed for the entire previous year, but did not file 1040, use Self-Employed Worksheet Cash Accounting Method Chapter 5 Program Eligibility

83. August 15 & 16, 2012 FFY2013 EAP Annual Training 83 Households With No Income  HH must complete the Inadequate Income Worksheet and provide documentation where requested  SP must obtain written or verbal verification of regular support from others reported on the worksheet  SP must determine eligibility based on documentation sent with the worksheet or verified during the follow-up  Failure to complete or return the worksheet is cause to deny the application as ‘Incomplete’ Chapter 5 Program Eligibility

84. August 15 & 16, 2012 FFY2013 EAP Annual Training 84 Households With Inadequate Income  Inadequate income means the household’s reported income is less than the household’s reported mortgage or rent payment  KEY to be certain this information is completed on the application AND entered into eHEAT Chapter 5 Program Eligibility

85. August 15 & 16, 2012 FFY2013 EAP Annual Training 85 Households With Inadequate Income  HH must complete the Inadequate Income Worksheet and provide documentation where requested  SP must obtain written or verbal verification of regular support from others reported on the worksheet  SP must determine eligibility based on documentation sent with the worksheet or verified during the follow-up  Failure to complete or return the worksheet is cause to deny the application as ‘Incomplete’ Chapter 5 Program Eligibility

86. August 15 & 16, 2012 FFY2013 EAP Annual Training 86 Households With No or Inadequate Income  If HH has no or inadequate reported income on their tax return when they are self-employed, tax return is sufficient to document no or inadequate income  SP must refer to advocacy and support services Chapter 5 Program Eligibility

87. August 15 & 16, 2012 FFY2013 EAP Annual Training 87 Households With No or Inadequate Income  New & Improved Worksheet—Appendix 5E  Spanish Worksheet available Chapter 5 Program Eligibility

88. August 15 & 16, 2012 FFY2013 EAP Annual Training 88 Expedited Verification  Eliminated  In all aspects –Crisis, ERR Expedited Verification To authorize assistance in the event of a crisis, expedite income verification and eligibility determination as much as possible. To expedite verification, obtain a verbal statement from the applicant stating that: To the best of the applicant's knowledge, the household's income qualifies for energy assistance. An emergency exists. The applicant promises to return emergency assistance funds if the household is found to be ineligible. After the immediate crisis has been addressed: Obtain the applicant's signature. Verify household income to confirm eligibility. Inform the applicant about the Service Provider's procedures and the applicant's responsibility. If the household is ineligible for the assistance, begin recoupment proceedings as described in Chapter 12 - Incidents and Appeals.Chapter 12 - Incidents and Appeals Chapter 5 Program Eligibility

89. August 15 & 16, 2012 FFY2013 EAP Annual Training 89 Q&A Program Eligibility