1. BCS Training Program Building A Strong Foundation
EAP Conference – September 26, 2018

2. BCS is grateful for the opportunity to present information on our training program, as well as procedural updates. Today we have:
Kathy O’Brien – CACD Co-Chief – Staffing Changes
Nancy Depew – TRAQU – Training Program
Matthew Hrivnak – Policy – Procedural Updates
Introduction

3. A Changing Workforce
There have been many staffing changes in the Bureau of Consumer Services (BCS) over the last several years. Vacancies created from retirements, transfers, and an influx of new staff necessitates a more structured approach to training in every division – Policy, Training/Quality Assurance (TRAQU) , and the Customer Assistance and Complaints Division (CACD).

4. New Staff – By the Numbers
CACD (Consumer Assistance and Complaints Division)
Our largest division, 60% of CACD staff are currently in training.
TRAQU
(Training, Quality Assurance)
50% of TRAQU staff have just over a year of in-bureau experience
Policy
25% of Policy staff are new or new to their position in the division.
New Staff – By the Numbers

5. Determining Training Needs
Historically, we replaced positions as they became vacant; training was accomplished by seasoned staff, many times one-on-one.
We changed the way we hire – now trying to group waves of 5-10 employees simultaneously, and needed to design a comprehensive training program around this approach.

6. Calculating Investment
People
Risk
Time
Effort
Sample 2
Before designing a new training program, we assessed our available resources. Our investments are staff-centered and staff-driven: hours for development, actual training time, post-training case review, and continuous training material improvements.

7. Training Program Objectives
TRAQU collaborated with CACD and Policy to identify key objectives, which include:
Ensuring consistency
Maximizing our staff resources
Advanced organization and tracking controls
Training Program Objectives

8. Collaborative Training Team
Our Training Team consists of a Training Supervisor and at least one subject matter expert from CACD to create new or build upon existing material and present the training; representative(s) from TRAQU to ensure consistency, tracking, updates, improvements and follow-up; and representative(s) from Policy that evaluate the trainees’ work before clearing them for independent case assignment.
Collaborative Training Team

9. Creating Building Blocks

10. Intake Consistent Core
Our first building block is Intake Training. Originally created for our Interviewers, this 2 week intensive course covers core information and concepts. All new staff must participate in this training to ensure consistency and a strong foundation, regardless of division.
Interviewers will eventually go on to learn more material specific to their duties as their training continues; Investigators will apply the skills learned in this course before moving on to the next training block.
Consistent Core
Intake

11. Termination Investigator Series
If an Investigator is hired, they move on to the first series of training courses for their classification with a focus on termination cases. Termination Investigators do not initially handle disputes. Their focus is on the less complicated casework.
Termination Investigator Series
Termination Investigator
Intake

12. Termination Investigator
As Investigators advance, they move to the next series of trainings that include the more complicated case types such as disputes, foreign load, theft, etc.
Investigator Series
Investigator
Termination Investigator
Intake

13. On-Going Training
We are continuing to revisit and enhance our training blocks, and we are currently developing more advanced training content for senior investigators.
Additionally, we utilize the slower winter months to offer all staff special in-house training and utility site visits. These have proven to be very beneficial to staff, especially newer investigators.

14. Procedural Updates

15. October 22, 2014 HB 939 or Act 155 of 2014 signed into law.
This law became effective December 22, 2014.
The Act reauthorized and amended Chapter 14 of the Public Utility Code (66 Pa C.S )(Responsible Utility Customer Protection).
Chapter 56 of the Pennsylvania Code at 52 Pa Code (relating to the standards and billing practices for residential utility service) must be revised because the amended Chapter 14 supersedes a number of Chapter 56 regulations.
Chapter 14 expires on December 31, 2024, unless reenacted.
Rulemaking to Amend the Provisions of 52 Pa Code Chapter 56 to Comply with 66 Pa C.S. Chapter 14

16. Notice of Proposed Rulemaking L-2015-2508421
July 21, 2016, the Commission adopted a Notice of Proposed Rulemaking (NOPR) to solicit comments about amending and adding provisions to Chapter 56 regarding the standards and billing practices for residential utility service. We asked the parties to comment on:
The form and content of a medical certificate
The reporting requirements for accounts exceeding $10,000 in arrearages
The definitions of applicant, customer, and public utility
Clarifying the 90-day deposit payment period
The expanded protection from abuse orders (PFAs) to include other court order
Material that should be included in the Commission’s privacy guidelines
Specific estimate of the cost and/or savings associated with these proposed changes
Notice of Proposed Rulemaking L

17. Notice of Proposed Rulemaking L-2015-2508421
July 12, 2017, the Commission issued an order seeking additional comments on its proposals and on issues raised by the comments. The Commission specifically invited comment on a few specific matters raised in the initial comments that we believed needed further vetting:
Privacy Guidelines At 66 Pa C.S. 1406(b)(1)(ii)(D)
Data On The Usage Of Medical Certificates
Cost And impact Of Regulatory Changes
We also introduced two new proposals:
Third-Party Notification Of Supplier Switching
2. Customer Retaining Utility Service Pending Formal Appeal
Notice of Proposed Rulemaking L

18. Notice of Proposed Rulemaking L-2015-2508421
Additional comments have been received and are now being reviewed by staff.
Comments are available on the PUC website by searching using the docket number.
Public comment period closed April 19, PUC submits final-form version of the regulation and response within two years--- April 19, 2019.
The regulation will be reviewed by IRRC and Committees
The Office of Attorney General will then review before final publication
Final regulation published in the Pennsylvania Bulletin
Contact Info: Matt Hrivnak, Manager of Compliance and Competition
(717)
Notice of Proposed Rulemaking L

19. Public Utility Company Dispute Procedures §56.151
Upon initiation of a dispute covered by this section, the public utility shall:
   (1)  Not issue a termination notice based on the disputed subject matter.
   (2)  Investigate the matter using methods reasonable under the circumstances, which may include telephone or personal conferences, or both, with the customer or occupant.
   (3)  Make a diligent attempt to negotiate a reasonable payment agreement if the customer or occupant is eligible for a payment agreement and claims a temporary inability to pay an undisputed bill. Factors which shall be considered in the negotiation of a payment agreement include, but are not limited to:
     (i)   The size of the unpaid balance.
     (ii)   The ability of the customer to pay.
     (iii)   The payment history of the customer.
     (iv)   The length of time over which the bill accumulated.
   (4)  Provide the customer or occupant with the information necessary for an informed judgment, including, but not limited to, relevant portions of tariffs, statements of account and results of meter tests.
   (5)  Within 30 days of the initiation of the dispute, issue its report to the complaining party. The public utility shall inform the complaining party that the report is available upon request.
     (i)   If the complainant is not satisfied with the dispute resolution, the utility company report must be in writing and conform to §   (relating to contents of the public utility company report). Further, in these instances, the written report shall be sent to the complaining party if requested or if the public utility deems it necessary.
     (ii)   If the complaining party is satisfied with the orally conveyed dispute resolution, the written utility company report may be limited to the information in §  56.152(1), (2) and, when applicable, §  56.152(7)(ii) or (8)(ii).
     (iii)   The information and documents required under this subsection may be electronically provided to the complaining party as long as the complaining party has the ability to accept electronic documents and consents to receiving them electronically.
Public Utility Company Dispute Procedures §56.151

20. Service is OFF Complaints
When a utility responds to an OFF complaint the utility report should include:
The date the termination notice was sent
If phone calls were attempted, the date, time, and outcome of those attempts
The amount the utility was requesting to stop the termination
Any contacts with the customer prior to the service being terminated
In addition, BCS is also requesting that utilities provide the investigator a copy of the termination notice for complaints in which the service has been terminated (including CURE cases). BCS needs a report and copies of the termination notice(s) before closing the complaint.
Service is OFF Complaints

21. Supporting Documentation
We ask that utilities provide BCS with copies of any written communications with the complainant when applicable to the complainant’s dispute. This includes:
Credit denial letters
Termination notices
Copies of medical certificates
Copies of any make-up bills
Any letters or reports sent to the complainant or written dispute reports on file related to §

22. Termination Notices and Supporting Documentation
Providing the requested documentation will help BCS in many ways:
Assisting the investigators when they speak with the complainant.
Allowing the investigators to gain a better understanding of the termination process.
Supporting BCS in developing and modifying our training materials.
Thank you for your willingness to help and for your anticipated cooperation!
Termination Notices and Supporting Documentation

23. Questions?