Energy Assistance Program

1. Energy Assistance Program FFY20 Annual Training Crisis; Energy Vendors; Energy Related Repair

2. Crisis Shamiere Bridgeford Minnesota Energy Assistance Program

3. Crisis Topics • Paying an arrearage • Delivered fuels • Biofuels • Standard Delivery Amount (SDA) • Biofuel: Crisis eligibility policy change • Biofuel: Crisis review • Crisis with shared meter • Secondary biofuel not redundant • Disconnection Letters

4. Crisis Paying an arrearage - Delivered fuels • Issue: SP or vendor is unable to verify whether HH tank is 20% or less and thus eligible for crisis when benefit will only be used to pay part/all of HH arrearage (no fuel delivery) • Decision: Reasonability checks are used to support likely Crisis eligibility when only paying an arrearage • 20% or less in fuel tank for LP or Oil • Less than 10 days of biofuel remaining

5. Crisis Paying an arrearage - Delivered fuels • Policy updates • Ch 7 Pg 5 Distributing Crisis Benefits section • Ch 7 Pg 13 Arrearage Guidelines section

6. Crisis Paying an arrearage - Delivered fuels • How to document • Reasonability checks should be performed • “Reasonability check” is used to confirm the emergency and Crisis eligibility should be documented in eHEAT • Should include last delivery date, gallons delivered and tank size • Notes in crisis screens as necessary

7. Crisis Paying an arrearage - Biofuels • Policy update • Ch 7 Pg 15 Less than 10 Days Biofuel and Arrearage Guidelines sections. • “Reasonability check” is used to confirm the emergency and crisis eligibility just as with delivered fuels • This is a reasonable estimate – not an exact science

8. Crisis Paying an arrearage – Biofuels • How to document • “Reasonability check” is used to confirm the emergency and Crisis eligibility • Biofuels “reasonability check” is documented in eHEAT event notes and should include last delivery date, annual consumption and amount delivered

9. Crisis Standard Delivery Amount (SDA) • What is an SDA and its purpose? • Solution implemented to replace use of minimum delivery amounts • Introduced in FFY15; clarified midyear FFY15 & retrained FFY16 • Addresses issue where small amounts are left in remaining crisis benefit • Improves efficiency by reducing HH need for repeat crisis • Maximizes benefits to HHs

10. Crisis Standard Delivery Amount (SDA) • How did we arrive at $600 for the SDA? • Statewide analysis of delivered fuel crisis’ (e.g., fuel prices, tank sizes) • JADs • State staff review ensures amount still makes sense Guess who?

11. Crisis Standard Delivery Amount (SDA) • Delivered fuels crisis benefit • Policy: Ch 7 pg 4 Amount of Crisis Benefit section • Up to $600 minus any amount that would leave a credit • Some exceptions may be allowable

12. Crisis Standard Delivery Amount (SDA) • Allowable exceptions to SDA must be documented • HH requests less than SDA • HH may need assistance with another emergency current or anticipated • Expected fuel delivery does not fit in the tank • Crisis benefit paying arrearage only; not enough resources to get a fuel delivery

13. Crisis Standard Delivery Amount (SDA) • Allowable exceptions to SDA must be documented cont. • Energy Vendor’s minimum delivery is greater than the SDA • Increase SDA onlyif the energy vendor’s required minimum delivery is over $600 and the PH benefit is being used as part of the Crisis benefit calculation • Example:

14. Crisis Standard Delivery Amount (SDA) • Yes or No? • The vendor’s minimum delivery amount is $175. Should I change the SDA? • The HH has concurrent emergencies for both their electric and propane service. Can I change the SDA? . . .work with the HH; as long as the HH has requested crisis for both • The HH has less than 20% and has a 500 gal propane tank, but the HH does not want a fill. They only want $200 of fuel delivered. Can I adjust the SDA? NO YES YES

15. Crisis Standard Delivery Amount (SDA) • Yes or No? cont. • Original, expected fuel delivery did not fit in tank. Can I adjust the SDA? YES. . .adjusting down is appropriate to match the actual fuel delivery • The energy vendor’s minimum is larger than the default $600 SDA and PH is being used as part of crisis calculation. Can I adjust the SDA up? (unlikely when fuel costs are normal to low) • My agency has a normal fixed amount of fuel for crisis events. Can I adjust the SDA? NO, this is not EAP Policy. Always use SDA unless an allowable exception. YES. . .

16. Crisis Biofuel crisis eligibility policy change • Policy change expanded crisis eligibility. Number of days of remaining biofuel increased from 7 to 10 days. • Policy Updates: • Ch 3 Pg 8 & Ch 7 Pg 2 Crisis Eligibility Requirements sections • Ch 7 Pg 15 Less than 10 Days Biofuel section • Why the change? • Minimizes risk of HHs running out of fuel due to increased delivery timeframes during peak demand periods

17. Crisis Biofuel crisis eligibility policy change • eHEAT screen update • Crisis reason updated

18. Crisis Secondary biofuel is not redundant • Issue: Biofuel heat sources (e.g., wood) require HH members to feed the fire to keep heat in the home • Decision: Policy updates do not consider biofuel secondary heat sources as redundant for ERR purposes due to frequent requirement of resupplying the fuel

19. Crisis Secondary biofuel is not redundant • Policy updates • Ch 7 pg 2 Crisis Eligibility Requirements section • Ch 7 pg 3 Redundant Heating section meter • Ch 8 pg 3 Furnace Terms and Definitions section • Ch 8 pg 4 ERR may not be used for section

20. Crisis Biofuel: Crisis confusion/clarification • Crisis benefit • HH uses EAP-registered wood vendor, crisis up to $600 • HH self-cuts wood, but uses EAP-register wood vendor for crisis, crisis up to $600 • HH self-cuts wood and no wood vendor (or seasoned wood) is available, individual crisis event gets up to $300 direct payment to HH

21. Crisis Biofuel: Crisis confusion/clarification • Avoid Crisis direct payments for self-supplied biofuel • SPs maintain knowledge of biofuel vendors in service area • Direct payments should only be made when SP confirms no other options are available (i.e. no EAP-registered vendor or useable biofuel such as seasoned wood available) • SPs must document direct pay reason in ‘Crisis’ screen notes

22. Crisis Crisis with shared meter – Clarification • New section “Shared Meters” added Ch 7 pg 3 • Why are we reviewing? • This question has come up several times via eap.mail during FFY19 • Reviewing to ensure policy is clear and program delivered consistently

23. Crisis Crisis with shared meter – Clarification • Crisis examples: Shared Meters • Two or more EAP HHs share a meter • Are both HHs eligible for the full $600? • How is it determined which HH uses their crisis grant to avoid the disruption? • Based on HH crisis request • Work with HHs on their unique situation • Be aware of private HH info and not sharing • One EAP HH shares a meter with a non-EAP HH • Is EAP HH eligible for the full $600? YES YES

24. Crisis Crisis with shared meter – Clarification • Review • HHs with unknown (e.g., shared meter, undesignated) heating costs or heat included in rent are eligible for a PH grant using the Backup Matrix • Crisis funds may be used to assist households sharing a meter with another household

25. Crisis Disconnection Letters – what’s required? • Investor owned utilities, during Cold Weather Rule (CWR) • Minn Stat 216B.096 • Notice requirement must include: • the date of the scheduled disconnection • the amount due • May not disconnect service: • earlier than 10 working days after notice mailing -or- • earlier than 7 working days after notice is personally served

26. Crisis Disconnection Letters – what’s required? • Investor owned utilities, outsidethe CWR • Minn Rules 7820.2400 • Notice requirements must: • include date on or after which disconnection will occur • reason for disconnection • methods of avoiding disconnection • be mailed via first class mail • May not disconnect service: • earlier than five days (excludes Sundays and legal holidays) • earlier than 7 working days after notice is personally served

27. Crisis Disconnection Letters – what’s required? • Cooperatives and municipal utilities, during the CWR • Minn Stat 216B.097 • Notice requirements must: • include a notice of proposed disconnection • May not disconnect service: • earlier than 20 days after the notice mailing -or- • earlier than 15 days after the notice has been personally delivered

28. Crisis Disconnection Letters – what’s required? • Investor owned utilities, during the CWR cont. Minn Stat 216B.096 • Subd. 7.Prohibitions and requirements. • (c) A utility may not disconnect service during the following periods: • (2) earlier than ten working days after a utility has deposited in first class mail, or seven working days after a utility has personally served, the notice required under subdivision 4 to a customer in an occupied dwelling;

29. Crisis Disconnection Letters – what’s required? • Cooperatives and municipal utilities, during the CWR Minn Stat 216B.097 • Subd. 2.Notice to residential customer facing disconnection. • Before disconnecting service to a residential customer during the period between October 15 and April 15, a municipal utility or cooperative electric association must provide the following information to a customer: • (1) a notice of proposed disconnection • Subd. 3.Restrictions if disconnection necessary. • Further, the disconnection must not occur until at least 20 days after the notice required in subdivision 2 has been mailed to the customer or 15 days after the notice has been personally delivered to the customer.

30. Crisis Disconnection Letters – what’s required? • Investor owned utilities, during the CWRMinn Stat 216B.096 • Subd. 4. Notice Before disconnection during cold weather period. • Before disconnecting utility heating service during the cold weather period, a utility must provide, personally or by first class mail, a commission-approved notice to a customer, in easy-to-understand language, that contains, at a minimum, the date of the scheduled disconnection, the amount due, and a summary of rights and responsibilities.

31. Crisis Disconnection Letters – what’s required? • Investor owned utilities, outsidethe CWR Minn Rules 7820.2400 • 7820.2400 NOTICE REQUIREMENTS. • Where required by this chapter, notice of impending action by the utility shall be by first class mail. • Disconnection notices shall contain the date on or after which disconnection will occur, reason for disconnection, and methods of avoiding disconnection in normal, easy-to-understand language. • All notice required by this chapter must precede the action to be taken by at least five days excluding Sundays and legal holidays. No notice may be given until the condition of which it informs, presently exists.

32. Crisis Disconnection Letters – what’s required? • Is this a valid disconnection letter? Why or why not? No date on service interruption Delivery through U.S. mail or personal delivery. This is an email.

33. Energy Vendors Jon Brown Minnesota Energy Assistance Program

34. Energy Vendors Topics • Delivered Fuel Discounts • Consumption

35. Energy Vendors Delivered Fuel Discounts • Delivered fuel vendors often offer a discount if bill is paid promptly or in cash following the delivery • Eligibility requirements for discount vary by vendor • Chapter 3 cites ­Minn. Stat. § 325E.027 – Fuel vendors must make available to EAP HHs any discount program that is made available to any other customer

36. Energy Vendors Delivered Fuel Discounts

37. Energy Vendors Delivered Fuel Discounts

38. Energy Vendors Consumption • Actual consumption cost is used to best reflect the HHs actual energy burden • Consumption costs should include, “Taxes and fees if typically a part of the heating bill.” • Consumption costs should NOT include irregular or non-routine costs like late charges, interest, leak tests, after hours trip charges, etc. • Key distinction is whether or not the HH is routinely or regularly charged these fees regardless of other circumstances

39. Energy Vendors Consumption • Example - A HH is charged interest on a delinquent account or a fee to have their tank tested because it was empty • If the HH was not behind on their account or did not let the tank go empty they wouldn’t be charged these fees • If certain fees are always charged regardless of HH circumstances then they would be considered “fees typically part of the heating bill” and should be included in the consumption costs • Examples: Hazmat fees, taxes, etc.

40. Energy Related Repair (ERR) Felicia Cullen Minnesota Energy Assistance Program

41. Energy Related Repair (ERR) Topics • ERR update: secondary wood not redundant • ERR file documentation • FFY19 ERR-related Findings & Recommendations • ERR HH required documentation • Invoice Requirements • Breakout – small groups

42. Energy Related Repair (ERR) FFY20 ERR Update • Redundant: Two interchangeable heating systems that heat essentially the same area. Dual furnace systems are redundant, e.g., LP furnace with an electric plenum furnace using the same blower and ductwork. Only electricity is needed to provide heat in this example. Because a biofuel heating system needs frequent resupplying of fuel, it is not considered redundant. Because a biofuel heating system needs frequent resupplying of fuel, it is not considered redundant.

43. Energy Related Repair (ERR) ERR File Documentation

44. Energy Related Repair (ERR) ERR Invoice Requirements • EAP ERR invoice must be itemized • Must include details of costs for labor and major parts (e.g. furnace, ductwork, thermostat, abatement) • Properly Itemized on the proposal or bid is acceptable • For SPs that do annual bidding • Itemized documentation from annual bidding must be available • Proper Itemization • For repairs: labor (rate x hours); major parts (quantity x price) • For replacements: furnace or boiler make, model and price; labor (rate x hours); major parts (quantity x price)

45. Energy Related Repair (ERR) ERR Invoice Requirements Unacceptable Invoice • No labor specifics (hours X rate) • No major parts specifics (quantity X price)

46. Energy Related Repair (ERR) ERR Invoice Requirements Acceptable Invoice • Labor specifics (hours X rate) • Major parts (quantity x price)

47. Energy Related Repair (ERR) ERR Invoice Requirements Discussion • Groups of 6 • Question 1 • Where do you think the breakdown is in contractor adherence to invoicing policy? • Question 2 • Where might there be gaps in your processes or internal controls that could lead to improper invoices being paid?

48. Energy Related Repair (ERR) ERR Invoice Requirements Discussion • Groups of 6 • Question 1 • How do you get contractors to adhere to invoicing policy? • Question 2 • What process does your staff follow to ensure invoices meet policy prior to payment?