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FFY 2011 Presented at FFY 2011 EAP Annual Training August 11 & 12, 2010 FFY 2011 Presented at FFY 2011 EAP Annual Training August 11 & 12, 2010 Section 2 content: § Chapter 1 Program Control Environment § Chapter 2 Overview of Service Provider Responsibility § Chapter 3 Vendor EAP Annual Training Section 2 (Of 6) 1

Chapter 1 Program Control Environment Chapter Content § Program Description § EAP Business Strategy Chapter 1 Program Control Environment Chapter Content § Program Description § EAP Business Strategy Model § EAP Internal Controls Framework (ICF) 2

Chapter 1 Program Control Environment Program Management Incremental Development Of EAP Business Models & Chapter 1 Program Control Environment Program Management Incremental Development Of EAP Business Models & Strategies § A number of concepts have been developed over time § Each added to EAP improvements & made a good program even better § Lately we have tried to more fully integrate these concepts into whole comprehensive approach 3

Chapter 1 Program Control Environment The Minnesota Model § § EAP employs a “Coordinated Chapter 1 Program Control Environment 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. 4

Chapter 1 Program Control Environment EAP Management Approach Proven Process Including § Project Plans Chapter 1 Program Control Environment EAP Management Approach Proven Process Including § Project Plans § Tools § Continuous Improvement 5

Chapter 1 Program Control Environment Formal & Documented Project Plans § Built with stakeholder Chapter 1 Program Control Environment Formal & Documented Project Plans § Built with stakeholder input § § § PAC EACA JAD State Staff Policy makers § Puts a well-understood and accepted process in place for reaching the project’s results 6

Chapter 1 Program Control Environment Approach by Advanced Strategies § Used to develop e. Chapter 1 Program Control Environment Approach by Advanced Strategies § Used to develop e. HEAT § Trained all EAP State Staff § Developed Internal Plans § Master Plan § Project Plans § Conducted JADs § Issues Management § Broadened application 7

Chapter 1 Program Control Environment Project (Effort) Definitions § Intentions: Goals or outcomes intended Chapter 1 Program Control Environment Project (Effort) Definitions § Intentions: Goals or outcomes intended § Values: Principles, standards and ideals incorporated into the project or effort § Focus: What’s included and excluded § Context: Situations existing around the project, not part of it but can affect it 8

Chapter 1 Program Control Environment Business Strategy Model Why Do We Need a BSM? Chapter 1 Program Control Environment Business Strategy Model Why Do We Need a BSM? Provides a Shared Vision § Gives people a sense we are all serving the same goals. . . we are all working together § Helps build a high-performing team § Helps provide consistent messages to key stakeholders § Helps guide day-to-day decisions and actions § BSM Intention Statement is our Mission – State Plan, Local Plan § We know you have heard it before but this is our basic foundation/strategy/mission 9

Chapter 1 Program Control Environment EAP BSM Intention Statement Maintain affordable, continuous, and safe Chapter 1 Program Control Environment EAP BSM Intention Statement Maintain affordable, continuous, and safe home energy for low-income Minnesota households 10

Chapter 1 Program Control Environment Vision What happens if we don’t have a shared Chapter 1 Program Control Environment Vision What happens if we don’t have a shared vision? § We each have a vision that underlies our behavior § If it is not shared – we appear to be § § § Out of sync Disorganized Inefficient Inconsistent Selfish Ultimately not worthy of confidence 11

Chapter 1 Program Control Environment The Business Strategy Model Handout in Folder Intentions Definitions Chapter 1 Program Control Environment The Business Strategy Model Handout in Folder Intentions Definitions · Why does your unit or organization exist? Values · What guides the behavior of your organization? Means · What products or services do we provide? · To whom do we provide them? Environments · What factors outside our organization must we monitor and adjust to? · How should we organize ourselves to meet our intentions, within our values? 12

Chapter 1 Program Control Environment Program Management EAP and PAC BSM Shared EAP & Chapter 1 Program Control Environment Program Management EAP and PAC BSM Shared EAP & PAC BSM are same except means, but share § Intentions § Values § Means (Offerings & Markets) § Environments 13

Chapter 1 Program Control Environment Program Management PAC BSM- Background How we got here Chapter 1 Program Control Environment Program Management PAC BSM- Background How we got here § § Developed for the program by the State Staff Extracted PAC specific content from a combination of program BSM and PAC effort definition 14

Chapter 1 Program Control Environment EAP BSM - Values 4 categories 1. 2. 3. Chapter 1 Program Control Environment EAP BSM - Values 4 categories 1. 2. 3. 4. Overall Regarding Households Regarding Collaboration Regarding Policy Direction 15

Chapter 1 Program Control Environment EAP BSM - Values 1. Overall a. Affordable, safe, Chapter 1 Program Control Environment EAP BSM - Values 1. Overall a. Affordable, safe, and dependable energy b. Advocacy c. Good stewardship of resources d. Being realistic about limitations e. Quality f. Partners and Partnerships (see Coordinated Responsibility Model) g. Understanding the program in the context of broader public policy and other needs of low-income Minnesotans h. Being the compass but not the map 16

Chapter 1 Program Control Environment EAP BSM - Values 2. Regarding Households a. Dignity Chapter 1 Program Control Environment EAP BSM - Values 2. Regarding Households a. Dignity and privacy b. Participation (see Coordinated Responsibility Model) c. Empower people to make informed decisions regarding their energy use and needs d. Serving the most in need – balancing total number of participants makeup of participants, and levels of service 17

Chapter 1 Program Control Environment EAP BSM - Values 3. Regarding Collaboration a. The Chapter 1 Program Control Environment EAP BSM - Values 3. Regarding Collaboration a. The responsibility to provide a safety net b. Working towards the same goals c. Stakeholders personal commitment and accountability d. Represent our own personal perspective, the views of our stakeholder group, and the world from multiple perspectives e. Actively coordinate across programs and departments 18

Chapter 1 Program Control Environment EAP BSM - Values 4. Regarding Policy Direction a. Chapter 1 Program Control Environment EAP BSM - Values 4. Regarding Policy Direction a. Creative and flexible approaches b. Consistency c. Balance of simplicity and fairness d. Recommendations based on a sound community analysis e. More strategic than operational d. Timely and proactive in order to mitigate emerging problems 19

Chapter 1 Program Control Environment EAP BSM - Means Offerings (Program Products & Services) Chapter 1 Program Control Environment EAP BSM - Means Offerings (Program 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 20

Chapter 1 Program Control Environment EAP BSM - Means Offerings State Staff Offerings § Chapter 1 Program Control Environment EAP BSM - Means Offerings State Staff Offerings § § § § Oversight, monitoring and quality control Compliance with Federal and State requirements Policy Decision making Planning Training and Technical Support Stakeholder involvement and communication Program advocacy and information 21

Chapter 1 Program Control Environment EAP BSM - Means Markets (Customers) § Households, emphasizing Chapter 1 Program Control Environment EAP BSM - Means 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 22

Chapter 1 Program Control Environment PAC BSM - Offerings § Direction § Oversight § Chapter 1 Program Control Environment PAC BSM - Offerings § Direction § Oversight § Advocacy, education and outreach 23

Chapter 1 Program Control Environment BSM Environments § Internal § External 24 Chapter 1 Program Control Environment BSM Environments § Internal § External 24

Chapter 1 Program Control Environment Internal Environmental Considerations Environmental Consideration Implications Unique & necessary Chapter 1 Program Control Environment Internal Environmental Considerations Environmental Consideration Implications Unique & necessary role of Households, Energy Vendors & Government (Coordinated Responsibility Model) Particular consideration to the definition and communication of all stakeholder roles Active pursuit of involvement and partnership by using a shared business methodology Increased likelihood of success Increased commitment of time on the front-end for all of stakeholders Devote scarce staff resources to the way we do business and invest in state staff skills and techniques Direction: Maximize local knowledge, control and delivery of services Contract out to local service providers State Office actively pursued feedback and adjustments Our leadership & peers are interested in and supportive of our efforts Understand align needs and expectations of leadership and peers Keep leadership and peers informed Our partners & community are interested in & supportive of our efforts Understand & align needs and expectations of partners and community 25 Keep partners and community informed

Chapter 1 Program Control Environment External Environmental Considerations Environmental Consideration Implications In the Office Chapter 1 Program Control Environment External Environmental Considerations Environmental Consideration Implications In the Office of Energy Security Primary state energy policy agency Not a social service agency – our offerings are unique in this organization Federal LIHEAP block grant Constraints and flexibility in how we deliver the program e. g. we determine to offer furnace repair and replacement There are other related programs (e. g. CWR, DHS, Heat Share and Affordability Programs) Effects public understanding, Resource amounts & timing of resources are out of our control Effects availability, delivery and types of services offer at program start up and dictates end date and carryover. Weather Effects demand during seasonal changes and effects consumption amounts Economy Increase demand on program services 26

Chapter 2 Overview of Service Provider Responsibility Chapter Description Page 1 § § § Chapter 2 Overview of Service Provider Responsibility Chapter Description Page 1 § § § Chapter outlines at a high level activities required of the EAP Coordinator & SP leadership. It outlines using Internal Controls Framework (ICF). Summarizes information detailed in the Policy Manual, referring to the appropriate chapter for policy details.

Chapter 2 Overview of Service Provider Responsibility Chapter Contents Page 1 § § § Chapter 2 Overview of Service Provider Responsibility Chapter Contents Page 1 § § § Control Environment Risk Assessment Control Activities Communication and Information Monitoring

Chapter 2 Overview of Service Provider Responsibility Training Topics § Advance EAP internal Controls Chapter 2 Overview of Service Provider Responsibility Training Topics § Advance EAP internal Controls & Framework by § Reviewing ICF understanding? § Reviewing where EAP is with ICF § Discussing what is next with ICF?

Chapter 2 Overview of Service Provider Responsibility What is ICF? The Framework is used Chapter 2 Overview of Service Provider Responsibility What is ICF? The Framework is used assess the Internal Controls maturity to determine how competently an organization risks § Identifies its § § Documents & assigns its control procedures How it monitors performance & effectiveness its procedures

Chapter 2 Overview of Service Provider Responsibility Page 1 Internal Control Definition Defines internal Chapter 2 Overview of Service Provider Responsibility Page 1 Internal Control Definition Defines internal control as a process, effected by individuals within an organization, designed to provide reasonable assurance regarding the achievement of these objectives: 1. Effectiveness & efficiency of operations 2. Reliability of financial reporting 3. Compliance with applicable laws & regulations.

Chapter 2 Overview of Service Provider Responsibility The Framework Interactions The Schnese Snow Globe Chapter 2 Overview of Service Provider Responsibility The Framework Interactions The Schnese Snow Globe illustrates the relationship if control frames

Chapter 2 Overview of Service Provider Responsibility 1. Control Environment Page 1 Service Providers Chapter 2 Overview of Service Provider Responsibility 1. Control Environment Page 1 Service Providers should establish and maintain an ethical and procedural work environment throughout the organization that sets a positive and supportive attitude toward internal control and conscientious management.

Chapter 2 Overview of Service Provider Responsibility Page 2 Service Provider EAP Organizational Competence Chapter 2 Overview of Service Provider Responsibility Page 2 Service Provider EAP Organizational Competence Service Providers should assure: § Service Provider human resource materials § A reasonable EAP resourcing model § EAP staff have functional position description § EAP staff have proper agency knowledge § EAP staff have proficient e. HEAT competencies § EAP staff demonstrate knowledge of Service Provider policies and procedures § Formal and new staff training § Support of technical environment necessary to deliver EAP § Training for staff to work with diverse populations

Chapter 2 Overview of Service Provider Responsibility Implementations Control Environment § Local Plan, contracts Chapter 2 Overview of Service Provider Responsibility Implementations Control Environment § Local Plan, contracts gives assurances by documenting internal controls competencies § SP connects Business Strategy Model (BSM) & SP Mission § SP participates in EAP management methodology including joint approach to development, EACA, JADs, training etc. § SP have realistic staffing model, structure of authority and show a commitment to EAP § Service Providers participates in EAP training and trains staff

Chapter 2 Overview of Service Provider Responsibility 2. Risk Management Page 2 Risk planning Chapter 2 Overview of Service Provider Responsibility 2. Risk Management Page 2 Risk planning is geared toward events that occur when things are different than planned. Service Providers should have procedures in place to deal with unplanned events. . . . The goal is assuring the Service Provider’s ability to maintain financial strength, a positive public image, and the overall quality of its products and government services.

Chapter 2 Overview of Service Provider Responsibility Risk Competence SP has risk a assessment Chapter 2 Overview of Service Provider Responsibility Risk Competence SP has risk a assessment process § Indentifying Internal and external risk § Assessing the impact and the likelihood these risks might occur § Selecting whether to avoid, reduce, share, or accept various risks § Considers controls to mitigate risk or to contain it to an acceptable level

Chapter 2 Overview of Service Provider Responsibility Implementations Risk Management § SP conduct risk Chapter 2 Overview of Service Provider Responsibility Implementations Risk Management § SP conduct risk assessment & mitigation activities § State and SP conduct oversight activities including: § Data, file and other checks § Data & Technology practices (e. HEAT user management) § SP make a maintain disaster plans § Local Employee Applications processes and utilization of state requirements § SP uses incident reporting process § SP uses error & fraud processes

Chapter 2 Overview of Service Provider Responsibility 3. Control Activities Page 3 Service Provider Chapter 2 Overview of Service Provider Responsibility 3. Control Activities Page 3 Service Provider should design and implement internal control in processing applications, determining eligibility and delivering benefits. These procedures assure program services are timely, accurate, uniform and equally available throughout the State. They address essential EAP required procedures

Chapter 2 Overview of Service Provider Responsibility Control Activities Competence § § There are Chapter 2 Overview of Service Provider Responsibility Control Activities Competence § § There are realistic policies & procedures to help ensure management directives are carried out Control activities occur throughout the organization at all levels in all functions

Chapter 2 Overview of Service Provider Responsibility Implementation Control Environment § SP processes have Chapter 2 Overview of Service Provider Responsibility Implementation Control Environment § SP processes have approvals & authorizations for benefit determination & payments (Separation of duties) § SP conduct and support verifications for: § § § Income eligibility & documentation vendor registration payment process for ERR contractors. Household check points SP conducts analytical procedures or quality controls SP conducts reconciliations like allocation and

Chapter 2 Overview of Service Provider Responsibility 4. Information & Communication Page 6 Service Chapter 2 Overview of Service Provider Responsibility 4. Information & Communication Page 6 Service Provider’s should communicate the internal control policies and procedures to all staff and stakeholders so they understand what is expected of them and the scope of their freedom to act in relation to program participants and partners.

Chapter 2 Overview of Service Provider Responsibility Information & Communication Competence § § § Chapter 2 Overview of Service Provider Responsibility Information & Communication Competence § § § Organization identifies, captures & communicates pertinent information in a timely manner to the right people to enable them to carry out their responsibilities Information systems are effective Internal information, and external events, activities & conditions are communicated to enable management to make informed business decisions and employees & partners to perform their roles & duties

Chapter 2 Overview of Service Provider Responsibility Implementation Communication & Information § § § Chapter 2 Overview of Service Provider Responsibility Implementation Communication & Information § § § SP has communication plan to dissemination information SP has routines, like meetings, to inform staff and partners SP conducts appropriate and effective outreach SP retains information over time SP is up to date with routine EAP communication: § Weekly newsletter The Energizer & Ad hoc email § Web information and program tools § Association meetings (Executive Directors & Coordinators)

Chapter 2 Overview of Service Provider Responsibility 5. Monitoring Page 6 Monitoring relates to Chapter 2 Overview of Service Provider Responsibility 5. Monitoring Page 6 Monitoring relates to Service Provider’s separate evaluations of internal control, such as control self-assessments or internal procedures and performance. . .

Chapter 2 Overview of Service Provider Responsibility Monitoring Competence: § § § Monitoring is Chapter 2 Overview of Service Provider Responsibility Monitoring Competence: § § § Monitoring is performed by management & supervisors on a continuous or periodic basis Identifying control deficiencies and reporting to top management and are remedied in a timely manner with appropriate corrective actions Is periodic follow-up on corrective actions taken to ensure control weaknesses are strengthened and no longer exist

Chapter 2 Overview of Service Provider Responsibility Implementation Monitoring § § SP uses performance Chapter 2 Overview of Service Provider Responsibility Implementation Monitoring § § SP uses performance goals like WACT to adjust resources SP measures average days from log to paid to monitor efficiency SP uses customer feedback SP monitors effect on production when implementing new tools or processes (Ex: Scanning)

Chapter 2 Overview of Service Provider Responsibility What is Controls Maturation § Internal Controls Chapter 2 Overview of Service Provider Responsibility What is Controls Maturation § Internal Controls mature as people become more aware of them § It becomes the culture and language § Results in improvement of Control Activities in a continuous improvement process § Risk management is strengthened

Chapter 2 Overview of Service Provider Responsibility Our Responsibility § Advance our understanding ICF Chapter 2 Overview of Service Provider Responsibility Our Responsibility § Advance our understanding ICF § Understand how existing EAP controls fit ICF § Continue to implement new ICF activities § Strengthening controls when weaknesses are detected § Provide supervision to ensure controls operate effectively § Obtain ICF information & training for selves & staff necessary to meaningfully take responsibility for internal controls § Share these Chapters with SP leadership

Chapter 2 Overview of Service Provider Responsibility ICF Improvements Next In FFY 2011 EAP Chapter 2 Overview of Service Provider Responsibility ICF Improvements Next In FFY 2011 EAP will focus on: § Advancing Risk Management § Improvement of self monitoring internal controls for continuous improvement § Continue framing is a way of organizing existing & then making improvement if needed § Everything you see is organized through ICF & this will continue

Chapter 3 Vendors Training Topics 1. Context 2. Chapter Structure 3. Policy & Procedure Chapter 3 Vendors Training Topics 1. Context 2. Chapter Structure 3. Policy & Procedure Changes § § § Refund Checks received After September 30 Sharing Data Vendor Agreement Improvements 4. Vendor Monitoring and Issues Management

Chapter 3 Vendors Important Context More scrutiny on vendor management from: § Events in Chapter 3 Vendors Important Context More scrutiny on vendor management from: § Events in Pennsylvania § General Account Office (GAO) § Investigator General (IG) § Federal & State continue to greater Internal Controls § Vendor controls are the major area of transactions

Chapter 3 Vendors State Plan Supplement DOC added Minnesota EAP Vendor Control Activities Summary: Chapter 3 Vendors State Plan Supplement DOC added Minnesota EAP Vendor Control Activities Summary: § Vendors are identified by households on application § Vendors enter into agreements with each EAP Service Provider § Vendor registers with the DOC and are entered into e. HEAT system § Vendor registers with Minnesota Management Budget (MMB) and are entered into accounting and procurement system. MMB validates duplications and bank accounts for EFT § When a payment is made to a vendor the household and vendor receives notification and transaction details § Service Providers conduct annual vendor monitoring and sample files and payment records

Chapter 3 Vendors Chapter Structural changes § § § Moved from Chapter 10 to Chapter 3 Vendors Chapter Structural changes § § § Moved from Chapter 10 to Chapter 3 Reduced sections from 17 to 6 Re-categorized information (Ex: Payment section now includes payment assignment, refunds and payments made in error)

Chapter 3 Vendors Page 1 Content § Consumption and Cost Information Requirements § Payment Chapter 3 Vendors Page 1 Content § Consumption and Cost Information Requirements § Payment Requirements § Crisis, Outreach, Advocacy & Other Service § § § Requirements Agreement, Registration & Participation Requirements Vendor Audit & Reporting Requirements Legal Requirements

Chapter 3 Vendors Policy Manual Clarification Page 4 Deliver Remaining EAP Benefits The vendor Chapter 3 Vendors Policy Manual Clarification Page 4 Deliver Remaining EAP Benefits The vendor should deliver any EAP benefit remaining on the household’s account before September 30. To avoid additional costs, delivery may be made during the vendor’s regular delivery route. If unable to deliver remaining EAP benefit, encourage households to leave the balance on the account for the upcoming heating season.

Chapter 3 (Also in Chapter 11) Vendors Delivered Fuels Refunds After September 30 Part Chapter 3 (Also in Chapter 11) Vendors Delivered Fuels Refunds After September 30 Part of overall efforts intended to: § Optimize the use of funds for fuel, § Reduce adverse public perception of the program Approach Taken: § Reduced promotion: Removed statement on letter saying household can ask for refund after September 30 § Advice HHD to use: SP & Vendors encourage households to keep EAP credits in active vendor accounts for future energy costs. § Deliver Credits pre-Sept. 30: SP work with delivered fuel vendors to identify EAP households with credits and use remaining credits during the program year.

Chapter 3 Vendors Delivered Fuels Refunds After September 30 Coming Soon § DOC will Chapter 3 Vendors Delivered Fuels Refunds After September 30 Coming Soon § DOC will collect information to understand the size & nature in early September § This information will be used to report to stakeholders and to determine if any future action is needed

Chapter 3 Vendors Policy Manual Vendor Data Practices Page 8 Sharing EAP Private Data Chapter 3 Vendors Policy Manual Vendor Data Practices Page 8 Sharing EAP Private Data With Vendors. . . The private household data collected by EAP has restricted uses. Generally, an EAP household’s consent allows their data only to be used for determining and delivering EAP services. . Any request for information must include an Informed Consent to Release Private Data signed by the household before requesting and receiving the information unless they are included in the EAP Application Permissions. Additional information is available in Chapter 14: Data Practices and Records of the EAP Policy Manual.

Chapter 3 Vendors Vendor Agreement Changes In Section I. , added #7 and #8 Chapter 3 Vendors Vendor Agreement Changes In Section I. , added #7 and #8

Chapter 3 Vendors Vendor Agreement Changes Reduced timelines for refunds requested by SP from Chapter 3 Vendors Vendor Agreement Changes Reduced timelines for refunds requested by SP from 30 days to 10 business days, and Process and refund all credits attributable to EAP payments within 10 business days after a client ceases to be a customer.

Chapter 3 Vendors Vendor Agreement Changes Removed statement about Vendor reporting difference of number Chapter 3 Vendors Vendor Agreement Changes Removed statement about Vendor reporting difference of number of HHD members from App

Chapter 3 Vendors Monitoring Page 6 Monitoring vendors is essential to ensure program quality Chapter 3 Vendors Monitoring Page 6 Monitoring vendors is essential to ensure program quality and integrity. An EAP vendor is bound by the requirements of the LIHEAP Act and the Vendor Agreement. Monitoring can also assure vendors follow these rules. Service Providers are required to monitor vendors.

Chapter 3 Vendors SP Monitoring Hat § SP act as a monitoring agent for Chapter 3 Vendors SP Monitoring Hat § SP act as a monitoring agent for EAP § SP validate key transaction § SP document findings, actions & outcomes § Looking for incidents of error or fraud

Chapter 3 Vendors Vendor Monitoring Process as A-Path-to-a- Solution Chapter 3 Vendors Vendor Monitoring Process as A-Path-to-a- Solution

Chapter 3 Vendors Definition to ensure quality & Integrity Page 6 Vendors must allow Chapter 3 Vendors Definition to ensure quality & Integrity Page 6 Vendors must allow the Service Provider and DOC access to their records for compliance monitoring. Monitoring includes verifying transactions between the vendor and the Service Provider. Including but not limited to cost information, application of payments to household accounts, billing to eligible households, providing equal services to EAP eligible households, and any or all other activities agreed to in the Vendor Agreement. Steps, on Page 6, help detail scope

Chapter 3 Vendors Analysis is discovery & Assessment § Take initial random sample § Chapter 3 Vendors Analysis is discovery & Assessment § Take initial random sample § If sample has issue, ask for larger sample. Additional discovery as needed can include: § Asking for explanation (In writing preferably) § Monitor determines the size in discovery depends on the vendor or risk level § Assess and specify the findings and their nature § Errors can be one-off or systemic § Do not start with fraud, if intent is questioned it is an investigation

Chapter 3 Vendors Design is determining actions Design actions based on findings: § If Chapter 3 Vendors Design is determining actions Design actions based on findings: § If a one-off error occurrence, document and close § If problem is systemic determine appropriate corrective action § If effect requires reparations to HHD harmed, determine process § If suspected fraud, develop an investigation and escalate (Incident Report) and pursue as related to policy § Document your requests and judgments

Chapter 3 Vendors Realize is acquiring solutions § Ask vendor to acquire, assemble or Chapter 3 Vendors Realize is acquiring solutions § Ask vendor to acquire, assemble or construct corrective actions § Vendor must construct solution § SP can support and validate § SP documents

Chapter 3 Vendors Implement is determining actions § The vendor is responsible to implement Chapter 3 Vendors Implement is determining actions § The vendor is responsible to implement solution § SP Monitoring is responsible to support § Vendor should communicate when it has been implemented § SP should document vendor communication

Chapter 3 Vendors Production is desired effect § Follow up to determine if issue Chapter 3 Vendors Production is desired effect § Follow up to determine if issue is corrected § May be next years visit or soon into the program year § Follow up depends on the risk related to severity of impact and probability of occurrence

Chapter 3 Vendors Rules of thumb Vendors Monitoring § Documentation is key § Keep Chapter 3 Vendors Rules of thumb Vendors Monitoring § Documentation is key § Keep to the facts and have vendor document responses § SP files are the program records § Team with other SP when effective § Follow up (Next year or sooner as needed) § Ask Field Representatives for help § Escalate as needed. May need to at any step in process

Chapter 3 Vendors Issue Management (Vendor) § Vendors need to work directly with SP Chapter 3 Vendors Issue Management (Vendor) § Vendors need to work directly with SP § It is not effective for DOC manage local relationships § Talk it through, describe what you are seeing § Work issues through the “Path” (but less formal) § Team with other SP § Escalate as needed. (FR can help ID these times to escalate)

Chapter 3 Vendors Consumption Record Changes If you find a record has changed during Chapter 3 Vendors Consumption Record Changes If you find a record has changed during year or during monitoring § Ask the vendor for the explanation § Do discover and assessment § Follow “Path” based on findings

Chapter 3 Vendors Consumption Record Changes Parameter: Consumption records can be changed for recalculating Chapter 3 Vendors Consumption Record Changes Parameter: Consumption records can be changed for recalculating the Primary Heat Benefit Tools to find facts § Vendor Agreement says vendor must contact SP if need to change consumption record § Previous consumption used is saved and visible on ‘Complete’ screen ‘screen for each time it is calculated § And on ‘Application Summary’ § e. HEAT now records creation date/user, last

FFY 2011 EAP Annual Training How to Train Vendors 101 § Ken Benson FFY 2011 EAP Annual Training How to Train Vendors 101 § Ken Benson

FFY 2011 EAP Annual Training How to Train Vendors 101 Basic Payment Step-By-Step § FFY 2011 EAP Annual Training How to Train Vendors 101 Basic Payment Step-By-Step § Go to ‘Payments’ menu § Demonstrate one criteria § Explain other criteria only if you think they are relevant to the particular vendor § Demonstrate export (if relevant) § Look at results – point out EFT # § Show to enter EFT in search criteria

FFY 2011 EAP Annual Training How to Train Vendors 101 Basic Vendors Payment Search FFY 2011 EAP Annual Training How to Train Vendors 101 Basic Vendors Payment Search Illustrated

FFY 2011 EAP Annual Training How to Train Vendors 101 Basics Application Step-By-Step § FFY 2011 EAP Annual Training How to Train Vendors 101 Basics Application Step-By-Step § Go to ‘Application’ tab § Click go § Be specific about what Benefits mean § Consumption § Vendor customer number edit

FFY 2011 EAP Annual Training How to Train Vendors 101 Basic Vendors Application Search FFY 2011 EAP Annual Training How to Train Vendors 101 Basic Vendors Application Search Illustrated

FFY 2011 EAP Annual Training How to Train Vendors 101 Change Account Number Illustrated FFY 2011 EAP Annual Training How to Train Vendors 101 Change Account Number Illustrated

Cold Weather Rule Energy Assistance Program Fall Training August 11, 2010 Public Utilities Commission Cold Weather Rule Energy Assistance Program Fall Training August 11, 2010 Public Utilities Commission Tracy Smetana 82

Public Utilities Commission • Regulates – local and in-state long distance telephone companies – Public Utilities Commission • Regulates – local and in-state long distance telephone companies – investor-owned electric and natural gas utilities – permitting for power plants, pipelines, transmission lines • Five Commissioners – appointed by Governor – serve staggered terms • 40 staff 83

Public Utilities Commission • Services provided by the Consumer Affairs Office – Mediation between Public Utilities Commission • Services provided by the Consumer Affairs Office – Mediation between customers and their utility companies – Consumer Education – Telephone Discount Programs – Cold Weather Rule – Utility Resource – Public Comments 84

Cold Weather Rule • Protects customers from having heat shut off in the winter. 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 85

Cold Weather Rule • Regulated CWR Companies – – – – Alliant Energy/Interstate Power Cold Weather Rule • Regulated CWR Companies – – – – Alliant Energy/Interstate Power & Light Center. Point Energy Community Utility Company Dakota Electric Association Great Plains Natural Gas Greater Minnesota Gas Island Gas Minnesota Energy Resources Minnesota Power Northwest Natural Gas of Murray County Northwestern Wisconsin Electric Otter Tail Power Xcel Energy 86

Cold Weather Rule Prior to CWR Season: • Bill inserts • Many utilities also Cold Weather Rule Prior to CWR Season: • Bill inserts • Many utilities also work to reconnect as many as possible. This step is not required by the Cold Weather Rule. 87

Cold Weather Rule CWR PAYMENT PLAN • Reconnect service OR prevent disconnection. • Available 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. • 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 88

Cold Weather Rule • Disconnect notice • Ten working days prior to disconnection date Cold Weather Rule • Disconnect notice • Ten working days prior to disconnection date • CWR “packet” must be included • What’s next? 89

Cold Weather Rule • Customer contacts utility – NO written application required – Household 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 90

Cold Weather Rule • Customer contacts utility – NO written application required – Household 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 91

Cold Weather Rule • Customer contacts utility – Utility and customer do NOT agree 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 92

Cold Weather Rule • Customer contacts utility – Customer fails to keep CWR payment Cold Weather Rule • Customer contacts utility – Customer fails to keep CWR payment plan • Customer subject to disconnection 93

Cold Weather Rule • Customer does not contact utility – Must investigate whether occupied Cold Weather Rule • Customer does not contact utility – Must investigate whether occupied or vacant • If vacant, proceed with disconnection • If occupied – Make contact, may require 2 nd visit – Offer CWR payment plan 94

Cold Weather Rule • Disconnection of service not allowed – While appeal is pending Cold Weather Rule • Disconnection of service not allowed – While appeal is pending – On Friday, unless CWR payment plan offered – On Saturday, Sunday, holiday or day before a holiday – When utility offices are closed – When no utility personnel available to make CWR payment plan – When Commission offices are closed 96

Cold Weather Rule • No deposit or late fees if household income at or Cold Weather Rule • No deposit or late fees if household income at or below 50% of state median • No disconnection during any appeal • Timely payment = within 7 calendar days 97

Cold Weather Rule • Cooperative/Muni CWR – Written application required – Applies only to Cold Weather Rule • Cooperative/Muni CWR – Written application required – Applies only to households at/below 50% of state median income – Appeal process does not include PUC – Requires 20 calendar day notice – Requires notice to Energy Assistance provider before disconnecting unoccupied residential unit – Reconnection provision recently added 98

Cold Weather Rule • Keys to protection – Contact utility company – Payment plan Cold Weather Rule • 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 99

Utility Programs • Electric Discounts – Xcel Energy • Required by law • Low Utility Programs • Electric Discounts – Xcel Energy • Required by law • Low Income households only (LIHEAP) – Eligible seniors and/or disabled, 50% off first 300 kwh – Affordability Program for eligible customers spending more than 3% of household’s annual income 100

Utility Programs • Electric Discounts – Minnesota Power • Available to all residential customers, Utility Programs • Electric Discounts – Minnesota Power • Available to all residential customers, regardless of household income • Tiered rate schedule • Proposal to change to a low income program pending 101

Utility Programs • Natural Gas Discounts – Center. Point Energy • Available to all Utility Programs • Natural Gas Discounts – Center. Point Energy • Available to all residential customers, regardless of household income • Tiered rate schedule 102

Utility Programs • Gas Affordability Programs (GAP) – Required by state law – Must Utility Programs • Gas Affordability Programs (GAP) – Required by state law – Must be LIHEAP recipient • Affordable monthly payment – Household pays percentage of monthly income » 4% for Xcel Gas customers » 6% for others – GAP funds pay the remainder • Arrearage forgiveness – – Household with arrears upon entering the program Customer pays a portion of arrears each month GAP funds match customer payment 12 -24 months • Greater Minnesota Gas – Waive monthly facility fee 103

Utility Programs • Conservation and Rebate Programs – Required by law • • Natural Utility Programs • Conservation and Rebate Programs – Required by law • • Natural Gas and Electric Utilities Investor-owned, Cooperatives, Municipals Percentage of revenue (varies by company type) Low income conservation program – Examples • • “Energy Star” appliance rebates Fluorescent bulb recycling programs Free/discounted energy audits Cycled central air conditioning 104

Life Support Households • Medical equipment requiring electricity necessary to sustain life is in Life Support Households • Medical equipment requiring electricity necessary to sustain life is in use. • 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. 105

Hot Weather Rule • No disconnection if National Weather Service issues… • Excessive heat Hot Weather Rule • No disconnection if National Weather Service issues… • Excessive heat watch • Heat advisory • Excessive heat warning • Applies to all electric utilities • Reconnection is not required 106

Public Utilities Commission Minnesota Statutes • 216 B. 091 Monthly Reports • 216 B. Public Utilities Commission Minnesota Statutes • 216 B. 091 Monthly Reports • 216 B. 096 Cold Weather Rule; Public Utility. Regulated Utilities • 216 B. 097 Cold weather rule, cooperative or municipal utility. • 216 B. 0975 Disconnection during extreme heat conditions. • 216 B. 098 Residential customer protections. • www. revisor. leg. state. mn. us 107

Telephone Discounts • Available to customers of – Traditional landline telephone service – Some Telephone Discounts • Available to customers of – Traditional landline telephone service – Some cellular – Not Voice Over Internet Protocol (VOIP) • Participate in qualifying program OR household income at or below 135% of federal poverty 108

Telephone Discounts • Qualifying programs Medicaid/Medical Assistance Food Support Minnesota Family Investment Plan (MFIP) Telephone Discounts • Qualifying programs Medicaid/Medical Assistance Food Support Minnesota Family Investment Plan (MFIP) Supplemental Security Income (SSI) Federal Housing Assistance (Section 8) Temporary Assistance to Needy Families (TANF) Low Income Home Energy Assistance (LIHEAP) National School Free Lunch Program Bureau of Indian Affairs General Assistance if living on a reservation Tribally Administered Temporary Assistance for Needy Families (TANF) if living on a reservation – Tribal National School Free Lunch Program if living on a reservation – – – – – 109

Telephone Discounts • Link Up – One time credit when hooking up new service Telephone Discounts • Link Up – One time credit when hooking up new service • Telephone Assistance Plan (TAP) • Lifeline – Minimum discount = $1. 75/month, up to $10/month • Application + proof of income to local telephone company • http: //www. puc. state. mn. us/PUC/consumers/telep hone-discounts/index. html • www. lifeline. org 110

PUC or AG? • • • Appliance repair programs =AG Cell phones = AG PUC or AG? • • • Appliance repair programs =AG Cell phones = AG Entertainment lines/900 calls = AG False advertising/marketing = AG Internet provider = AG Landlord/tenant issues = AG Military personnel utility payment plans = AG Non-utility charges on telephone bill = AG Recording telephone calls = AG State to state or international long distance = AG Voice Over Internet Protocol (VOIP) = AG • 651 -296 -3353 or 1 -800 -657 -3787 • www. ag. state. mn. us 111

Public Utilities Commission Tracy Smetana Consumer Mediator Minnesota Public Utilities Commission 121 Seventh Place Public Utilities Commission Tracy Smetana 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 Public. Comments. puc@state. mn. us www. puc. state. mn. us 112