Gate 03: Draft Recommendation Report - CPW070c - MOSL

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Gate 03: Draft Recommendation Report

CPW070c: Phase 3 - Bilateral Transactions Summary

The Authority (Ofwat) published its Authority Timetabled Change Proposal

for the bilateral transactions programme (i.e. Change Proposal

CPW070/CPM043) in June 2021.

This draft recommendation report (DRR) sets out the code amendments

necessary to deliver three new processes into the Bilateral Hub. These

processes are F4 (enquiries), F5 (complaints) and G1 (Trade Effluent

enquiries).

CPW070c also seeks to introduce a Wholesaler-initiated version of F4 and

F5 to reflect the reality that Wholesalers, in many cases, already progress

enquiries and complaints from customers who approach them directly,

which will help to improve the customer journey, rather than referring them

back to their Retailer.

Finally, this proposal seeks to change one as-yet implemented transaction in

B5 (meter repair and replace).

Recommendation

Panel is invited to:

• AGREE to recommend the code amendments

of CPW070c

• AGREE to recommend an implementation

date of 31 May 2022 if Ofwat approval is

received by 31 March 2022

Impacts

• Non-Household Customers

• Trading Parties

o Wholesalers

o Retailers

• MOSL

What stage is this

document in the process?

Change Proposal 01

Consultation 02

Draft Report 03

Final Report 04

Proposer

Dan Mason, Ofwat

Questions? Contact: Evan Joanette [email protected] 07948 466722

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Contents

Background ................................................................................................................................... 3

Case for change ............................................................................................................................. 3

Solution - Code Amendments ....................................................................................................... 5

Impacts ....................................................................................................................................... 13

Industry Engagement .................................................................................................................. 15

6 Panel Decision ............................................................................................................................. 18

Appendix 1: Advisory Groups .............................................................................................................. 19

Appendix 2: Code Documents amended for this change .................................................................... 25

Appendix 3: Customer journeys .......................................................................................................... 26

About this document

This document is the Draft Recommendation Report (DRR) for Change Proposal CPW070c.

This DRR provides information on the changes required to specific code documents listed

below to align them with the technical solution.

Hyperlinks to Wholesale Retail Code (WRC) (clean & tracked) documents in Appendix 2.

• Schedule 1, Part 3: Operational Terms

• OSD 0703 Bilateral Processes for Part B - Metering

• OSD 0707 Bilateral Processes for Part F – Monitoring, investigations, complaints and

enquiries

• OSD 0708 Bilateral Processes for Part G – Trade Effluent

• Annex F – Process Diagrams

• Annex G – Process Diagrams

• CSD 0002 Market Performance Framework

• CSD 0302 Standing Reports and Data Extracts

• CSD 0601 Bilateral Data Catalogue

• Form F/01

• Form F/02

• Form G/01

Hyperlinks to other key documents

• CPW070/CPM043 Change Proposal form;

• Change log

Further information

For further information, please see the Change Proposal on the MOSL website or contact

the Panel Secretariat via [email protected].

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Background

Operational processes are set out in the Wholesale Retail Code (WRC). At market opening,

no centralised bilateral transaction solution was put in place to deal with these operational

processes. Therefore, Trading Parties1 developed their own solutions to deliver them.

The Authority proposed an Authority Timetabled Change Proposal CPW070/CPM043:

‘Bilateral Interfaces Solution’ in July 2019, which has subsequently been amended twice,

with the most recent version published in June 2021. Change Proposals CPW070/CPM043

set out the development of a centralised bilateral solution (i.e. a centralised Bilateral Hub)

taking a more agile approach, with delivery of processes in phases.

The timetable set out a governance structure with more detail in the Programme Initiation

Document. Advisory group key decisions are in Appendix 1 and all meeting minutes and

support material are published on MOSL’s website here. Detail of the last internal audit

report was published in August 2021.

The Panel agreed to recommend the first stage, CPW070a/CPM043a: Phase 2 – Bilateral

Transactions, in June 2021 and CPW070a-1 in August 2021 to Ofwat for approval. Ofwat

approved both changes, which were implemented on 22 September 2021, bringing the

Bilateral Hub and the C1 process (Verification of meter details or supply arrangements) into

effect. The Panel then recommended CPW070b-1 in December 2021 which set out

additional functionality and the B5 process (Meter Repair or Replace). In January 2022,

Ofwat approved this Change Proposal for implementation in two stages on 2 February and

31 May 2022.

Case for change

The detailed case for change, including the Full Business Case (FBC) for the bilaterals

programme, is set out in the CPW070a/CPM043a Final Recommendation Report (FRR). The

overall purpose of CPW070/CPM043 is to develop a standardised approach to bilateral

transactions, supported by a technology platform, i.e. the Bilateral Hub.

Specifically, CPW070c is needed to:

• Introduce code provisions to implement three additional processes within the

Bilateral Hub:

1. F4 process (Non-Household Customer enquiries)

2. F5 process (Non-Household Customer complaints); and

3. G1 process (Trade effluent enquiries)

• Bring the code in line with a desirable market behaviour whereby some Wholesalers

initiate F4 or F5 processes even though Market Codes require Retailers to do so.

1 Unless otherwise specified, the terms used in this document are those defined in the WRC

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• Adjust a transaction in the as-yet implemented B5 process (Repair or replacement of

a faulty meter performed by the Wholesaler) so that it can be used for future

processes.

2.1 Assessment against the MAC and WRC Principles and Objectives

Table 1: Summary of Proposer’s view against the Objectives & Principles

Objective & Principle

Benefit

Primary Principle

The interests of Non-Household Customers are better protected and promoted by the provision of a standardised approach to bilateral transactions, including end-to-end Key Performance Indicators (KPIs)/Service Level Agreements (SLAs) and better, centralised monitoring. Clearer code drafting that explains how Requests should be raised will help Trading Parties work together more effectively to deliver the outcomes that have a positive effect on the customer experience. Adding a Wholesaler-initiated component to the F4 and F5 processes will provide a better customer journey whereby Wholesalers who are able can progress an enquiry or complaint if a customer contacts them directly, preventing many customers from being referred backward and forward between Wholesalers and Retailers.

Simple, cost effective & secure

CPW070c seeks to establish the F4. F5 and G1 processes within Central Systems which will enable Trading Parties to transact in a straightforward and consistent manner in relation to these processes. Validation rules support data integrity for relevant operational process.

Efficiency

Implementation of the F4, F5 and G1 processes in the Bilateral Hub will help to enable the efficient operational of the competitive market through the facilitation of more effective communication between Trading Parties in relation to these processes. This solution re-uses Data Transactions and Data Items developed for processes which have already been implemented in the Bilateral Hub. The proposed change to the B5 transaction would deliver development efficiency for MOSL and Trading Parties for this and future implementations. This solution seeks to bring the F4, F5 and G1 processes within the Bilateral Hub’s centralised reporting capabilities (including the F5 process’ OPS), offloading the burden from Trading Parties.

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Objective & Principle

Benefit

Proportionality

Evidence suggests that F4, F5, and G1 processes should be prioritised for inclusion in the Bilateral Hub at a relatively early stage as they are customer-led and there are efficiencies to be gained from developing them in parallel. The approach to amending the wholesale retail code (WRC) is proportionate as it builds on code already developed.

Transparency & clarity

The Bilateral Hub will improve the transparency of the relevant operational processes making it easier for Trading Parties to supply the right information, follow the right steps, meet process requirements and report consistently. MOSL will be able to report and publish performance data relating to the F4, F5 and G1 processes which has been collected in a standardised way through the Bilateral Hub.

Non-discrimination

Delivers a standardised solution which will support all Trading Parties in being able to carry out processes F4, F5 and G1 consistently.

2.2 Implementation Dates

The F4, F5, and G1 processes are being developed in parallel and engagement with the

industry has established 31 May 2022 as the earliest appropriate implementation date for

CPW070c. The B5 process which was part of CPW070b-1 and has been approved by Ofwat is

also scheduled for implementation on 31 May 2022.

Solution - Code Amendments

MOSL has worked with the Operational Advisory Group (OAG) and the wider Trading Party

(TP) community to determine an approach to prioritising the development of the bilateral

processes. Following the C1 and B5 processes, F4, F5 and G1 were prioritised as they are

customer-led and have similar functional characteristics that mean it is more efficient for

them to be developed and implemented together.

In terms of form, CPW070c combines a review and clarification of the F4 and F5 processes

by the OAG and its adaptation into clearer code architecture (i.e. standalone Operational

Subsidiary Document OSD 0707) by CAG.

As with previous processes, code documents have been reviewed by MOSL subject matter

experts (SMEs), MOSL legal counsel, with input from Ofwat. All code amendments were

reviewed and recommended by the CAG in line with established programme governance.

A list of changed code documents are in sections 3.1 to 3.4.

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3.1 F4 Process

• Schedule 1, Part 3: Operational Terms

• OSD 0707 Bilateral Processes for Part F - Monitoring, investigations, complaints and

enquiries

• CSD 0302 Standing Reports and Data Extracts

• CSD 0601 Bilateral Data Catalogue

• Annex F Process Diagrams for Part F

• Form F/01 (withdrawn)

3.2 F5 Process

• Schedule 1, Part 3: Operational Terms

• OSD 0707 Bilateral Processes for Part F - Monitoring, investigations, complaints and

enquiries

• CSD 0002 Market Performance Framework

• CSD 0302 Standing Reports and Data Extracts

• CSD 0601 Bilateral Data Catalogue

• Annex F Process Diagrams for Part F

• Form F/02 (withdrawn)

3.3 G1 Process

• Schedule 1, Part 3: Operational Terms

• OSD 0708 Bilateral Processes for Part G – Trade Effluent

• CSD 0302 Standing Reports and Data Extracts

• CSD 0601 Bilateral Data Catalogue

• Annex G Process Diagrams for Part G

3.4 Miscellaneous

• OSD 0703 Bilateral Processes for Part B – Metering

• CSD 0601 Bilateral Data Catalogue

A summary of key amendments by theme are set out in Table 2. A full log of all changes and

the rationale for these changes is set out in the change log.

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Table 2: Summary of key amendments to deliver CPW070c

Code amendment theme & description

Code documents affected and details of the amendments

Rationale and impacts

Amendment to code

architecture for the

F4, F5 and G1

processes

Schedule 1 Part 3 Operational Terms

• Process steps for Processes F4, F5, and G1 have

been moved out of the Operational Terms and into

OSD 0707 (Bilateral Processes for Part F) and OSD

0708 (Bilateral Processes for Part G) and replaced

with signposting to the relevant OSDs.

Rationale: This approach is consistent with the code

architecture for the previous processes, C1 and B5 and in

line with OAG and CAG recommendations.

Impact: OSDs provide single key reference for a family of processes (e.g. step-by-step processes, SLAs, flow diagram). This contributes to simplifying the code structure and improves the efficiency of code navigation for Trading Parties.

Updates to F4, F5 and

G1 process diagrams

Annexes F & G – Process Diagrams

• Process flow diagrams to be contained within the

OSD where the process steps are described.

Therefore, process flow diagrams for F4 and, F5 and

G1 are moved to OSD 0707 and the process flow

diagram for the G1 process has been moved to OSD

0708. These diagrams have been struck out of

Annexes F and G.

Rationale: This approach is consistent with the code

architecture for the previous processes, C1 and B5 and in

line with OAG and CAG recommendations.

Impact: OSDs provide single key reference for a family of processes (e.g. step-by-step processes, SLAs, flow diagram). This contributes to simplifying the code structure and improves the efficiency of code navigation for Trading Parties.

Specific process steps

to complete F4 and F5

processes

OSD 0707 Bilateral Processes for Part F – Monitoring,

investigations, complaints and enquiries

• Process steps inherited from Operational Terms and

reviewed by MOSL SMEs and OAG.

Rationale: Wholesaler-initiated versions of the F4 and F5 processes have been created to reflect that Wholesalers often initiate F4 and F5 processes because it is a better customer journey than referring an unhappy customer back to their Retailer when the Wholesaler is perfectly capable of progressing the matter.

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Code amendment theme & description

Code documents affected and details of the amendments

Rationale and impacts

• F4 and F5 processes have codified resubmission

pathway to avoid having to start anew if there are

problems with the initial submission.

• Creates new Wholesaler-initiated versions of F4 & F5

• F5 OPS measure strengthened

• Redundant 5-day acknowledgement SLA removed as

the Bilateral Hub acknowledges Requests as soon as

they’re submitted.

• Clarification that GSS obligations sit separately to OSD

0707. GSS exemptions no longer tied to an OPS

measure.

• F4 and F5 processes have a new Data Item to indicate

if there is a follow-on process or work to do.

• F4 and F5 timeframes which were not explicitly laid

out in the Operational Terms are now clear SLAs

within tables in OSD 0707.

• Incorporated Annex diagram for F4 and F5 processes

to simplify code navigation.

Removing the requirement (though still allowing the option) for Wholesalers to refer customers to their Retailer should contribute to improved customer experience and reduced waiting times for resolution of complaints and queries. A more robust F5 OPS ensures that Wholesalers are held to a performance standard until they provide a substantive response. See more detail below (CSD 0002). The ability to track and report on whether there is a follow-on action following a complaint or enquiry provides a better dataset to drive improved outcomes for customers. Impact: HVI Wholesalers must build a new Wholesaler-initiated process. Wholesalers that are not able to initiate an approach from a customer as an F4 or F5 can still refer them to the Retailer, so customers would be no worse off than they are with the status quo. Changes to the F5 process reviewed with CCW to ensure that more customer complaints (those taken up initially by Wholesalers) could be accommodated as a Bilateral Process (and thus be part of the Market Performance Framework) which would in turn provide timelier responses and outcome to customer complaints, better performance monitoring (driving improved behaviours). CCW, MOSL and Ofwat reviewed code to ensure that proposed amendments would not impact GSS.

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Code amendment theme & description

Code documents affected and details of the amendments

Rationale and impacts

The Bilateral Hub’s validation and resubmission modules are used again, which will support Trading Parties in starting, or quickly restarting, an F4 or F5 Request, rather than seeing them close unilaterally by the Wholesaler.

Specific process steps to complete G1 Process

OSD 0708 Bilateral Processes for Part G – Trade Effluent

• Process steps inherited from Operational Terms and

reviewed by MOSL SMEs and OAG.

• The F4 and F5 have a new Data Item to indicate if

there is a follow-on process or work to do.

• G1 timeframes which were not explicitly laid out in

the Operational Terms are now clear SLAs within

tables in OSD 0708.

• Incorporated Annex diagram for G1 process to simplify code navigation.

Rationale: Standalone OSD incorporates redesigned G1

process steps into existing steps taken from the

Operational Terms, process flow diagrams and SLA table.

The ability to track and report on whether there is a follow-on action provides a better dataset to drive improved outcomes for customers. Impact: OSDs provide a single document to reference key information about a family of processes (e.g. step-by-step process, SLAs, and flow diagram).

Changes to KPIs and

centralised reporting

CSD 0002 Market Performance Framework

• F5 Operational Performance Standard (OPS)

strengthened so there is no longer a Wholesaler

ability to satisfy an OPS by invoking GSS rules and

indicating that are unable to provide a substantive

response. Wholesaler can defer if necessary, but

within the MPF must provide a substantive response.

• Removed F5 related OPS measures from Section 4

(which sets out Trading Party-reportable OPS) and

Rationale: Streamlines two OPS measures (F5a, F5b) into

one (F5-2 which is more customer-outcome focussed) in

line with OAG preference and MPF subgroup direction of

travel and in keeping with C1 and B5. Without this

change, where the Wholesaler determines they needn’t

respond to a complaint (rightly or wrong as per the

exemptions set out in GSS), there is no subsequent

standard to ensure a substantive reply is ever given to the

customer. F5-2 creates a requirement to always respond

substantively.

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Code amendment theme & description

Code documents affected and details of the amendments

Rationale and impacts

added new F5-2 OPS measure to Section 5 (centrally

reportable OPS).

Impact: Clear customer-outcome focused OPS makes it

easier for Retailers and Non-Household Customers to

understand when Requests are finished.

F5 OPS reporting will be performed centrally, removing a

burden on Wholesalers to do so.

Standing Reports and

data extracts

provided by the

Market Operator on a

systematic basis.

CSD 0302 Standing Reports and Data Extracts

• Additional drafting to explain the origin of data for

the Bilateral Hub SLA Detailed Report, incorporating

F4, F5 and G1 processes.

Rationale: New Data Items will be brought online which

need to be identified as part of standing Reports.

Impact: A fulsome set of Data Items accessible via standing Reports will enable Retailers and Wholesalers to monitor their service for business intelligence and performance purposes. Availability of a more fulsome dataset can also be used to inform market improvement initiatives to drive improved outcomes for customers.

Data catalogue (Data

Items and Data

Transactions) that

underpin bilateral

transactions.

CSD 0601 Bilateral Data Catalogue

• New F4, F5 and G1 Transactions T222.W (Service Request Complete) &

T222.M (Notify Service Request Complete).

• New F5 transactions T501.R, T501.W-Submit Non-Household Customer

Complaint, T501.M-Notify Non-Household Customer Complaint,

• New F4 transactions T505.R, T505.W-Submit Non-Household Customer Enquiry T505.M-Notify Non-Household Customer Enquiry,

• New G1 transactions

Rationale: New Data Items and Data Transactions are

needed to enable new processes to function within the

Bilateral Hub and must be identified as part of CSD 0601

Bilateral Data Catalogue to facilitate Trading Party

development, training, and reporting.

Impact: Series of new asset-related Data Items will allow MOSL and Trading Parties to do more detailed analysis of asset fixes and asset data corrections. Maintains format of CSD 0301 – Data Catalogue with which Trading Parties are familiar

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Code amendment theme & description

Code documents affected and details of the amendments

Rationale and impacts

T551.R, T551.W-Submit Non-Household Customer TE Enquiry, T551.M-Notify Non-Household Customer TE Enquiry

• New state transitions, data items and valid sets to support F4, F5, & G1

• New Data item D8366 added for T291.M to better indicator if a Service Request originated with the Retailer or Wholesaler

• DISPOUTCOME added to D8231 Resubmit Reason Code

• Data item D8322; new valid set value, ‘THIRDPARTY’ added for T291.M to help with notifications to ‘Other Retailer’.

Data Protection Impact Assessment (DPIA) is being undertaken as it was for previous implementations to ensure that new Data Items related to F4, F5 and G1 processes are identifiable should they contain or lead to personally identifiable data.

Initiating F4, F5, and

G1 processes

F/01, F/02 and G/01 Forms

• Forms will be withdrawn

Rationale: Requests for these processes should no longer

be initiated through Forms following implementation into

the Bilateral Hub because initiation will be done via the

Hub’s Low Volume Interface (LVI) or through integration

with Trading Party systems where the High Volume

Interface (HVI) is being used.

Impact: Bilateral Hub will validate data ensuring better quality information is sent from Retailer to Wholesaler and fewer Requests are subsequently rejected. Provides a more seamless experience for Non-Household Customers.

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Code amendment theme & description

Code documents affected and details of the amendments

Rationale and impacts

Amends B5 process to provide Transaction efficiency

OSD 0703 Bilateral Processes for Part B – Metering

• Data Transaction T353.W Propose Exchange or Repair Plan replaced with T224.W Advise Process Delay

CSD 0601 Bilateral Data Catalogue

• Data item D8227 Valid set changed to add (PREPWORK) to support creation of T224.W Advise Process Delay and removal of T353.W Propose Exchange or Repair Plan (including .M versions)

Rationale: T353.W was developed to work for B5, but it was later recognised that if it was made more generic, this Data Transaction could be used for several future processes, and therefore T224.W was created substituted in place of T353.W. Impact: Amends a transaction in B5 which was already recommended by Panel. However, this is not due for implementation until 31 May 2022. Amendment has been communicated widely to industry with lots of lead time. Principles set out by the OAG, TAG, Contract Managers and the wider industry is that the Bilateral Hub should require as few new Data Transactions as possible as this is more efficient.

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3.5 Code amendments for consideration after CPW070c

Bulk submission of Requests:

During development of the Bilateral Hub as part of CPW070a/CPM043a, it was identified

that the HVI could be used to submit Requests in an equivalent way to a bulk submission

tool. The interaction with the Ofwat decision on CPW067 – bulk submission via MS Excel

was identified by the CAG.

To address concerns without delaying implementation, Ofwat required MOSL to work with

Trading Parties to develop interim guidance to mitigate the risk of customer detriment

where bulk submission may occur in the Bilateral Hub.

However, Ofwat expects an enduring solution to be in place as soon as possible and MOSL is

working with Trading Parties to deliver this solution which would replace the guidance

document. MOSL expects to present a codified solution to the Code Change Committee in

March 2022.

Impacts

4.1 Full Business Case

The Full Business Case sets out programme objectives are set out in Section 2, and the scope

of the programme set out at Section 3 and Section 4 of the Authority Timetabled Change

Proposal which were developed to deliver the key objectives.

The Full Business Case was approved by Trading Parties and MOSL is fully funded for the

financial year 2021/22 and additional funding will be outlined as part of the ‘business as

usual’ business planning for the next financial year.

4.2 Customer Impacts

4.2.1 View of customer representative

CCW continues to support the aims and objectives of the Bilateral Transactions Programme,

and is particularly supportive of the prioritisation of the F4 & F5 process changes. It is

positive that MOSL recognised the significant customer impact that these processes have,

and prioritised reform in this area accordingly. As with the previous process changes, a

clearer set of centralised standards should result in Trading Parties working together more

efficiently, which should result in improvements to the customer experience. In addition, we

agree that validation of data in the Bilateral Hub should improve the quality of information

shared between Trading Parties, thereby resulting in a more seamless experience for

customers.

We are particularly supportive of the proposed Wholesaler-initiated F4 & F5 processes.

Where wholesalers are able to handle complaints and queries directly, it is logical from a

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customer perspective to allow them to address the issue, while keeping the Retailer

informed. Customers being re-directed unnecessarily from Wholesaler to Retailer results in

a poor experience for the customer, so this change is positive.

While allowing Wholesalers to handle certain requests has benefits for customers, it would

be inappropriate for them to attempt to address issues better dealt with by Retailers. We

are not advocating being prescriptive in terms of the issues Wholesalers can deal with, but

the division between Retailer and Wholesaler responsibilities should be clear so as to avoid

a poor experience for the customer. We would urge MOSL to include wording within the

relevant process which addresses this point.

In the event of a Wholesaler-initiated process, it is positive that there is a requirement for

the retailer to be informed of the proposed resolution. However, if the customer has

contacted the Wholesaler directly, it would be a better experience if the wholesaler

responded rather than the Retailer. While it may not be the best place to reflect this in a

process governing Retailer and Wholesaler transactions, we would urge for best practice

guidance to be developed in this area to ensure that customer confusion is avoided. This

may be something that the RWG could look to develop if this change proposal is approved.

4.2.2 Improvements to customer journey

The additional functionality and introduction of the F4, F5 and G1 processes will create

efficiency and more seamless experiences for customers. In particular, the creation of

Wholesaler-initiated F4 and F5 processes will eliminate the need for customers to be

“passed from pillar to post” where a Wholesaler who received the initial customer contact is

willing and able to affect the resolution to the query.

MOSL and CCW worked together to illustrate how CPW070c can lead to better Non-

Household Customer journeys in Appendix 3.

4.3 Trading Party Impacts

4.3.1 Code Implementation

While the costs of CPW070c cannot specifically be isolated, the bilateral transaction

programme’s Full Business Case (section 3) outlines project costs of which assessment,

implementation and ongoing operational costs are borne by Trading Parties as they will

have to ensure their business processes align to new code requirements and staff are

trained to use the Bilateral Hub.

4.4 MOSL Impacts

4.4.1 Programme delivery

A core programme delivery strategy is to provide an MVP (minimum viable product)

solution, whilst identifying and delivering additional MVP+ functionality, where budget and

timelines allow.

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MOSL has worked carefully with the OAG to ensure a MoSCoW (‘Must, Could, Should,

Won’t’) analysis has been done, in particular on the F5 process where some newly

proposed, but ultimately resource-intensive functionality, was not considered MVP.

The implementation of CPW070c has required the creation or amendment of code

documents, the technical solution design and system build within the Bilateral Hub and

operational process redesign to underpin the solution to allow the implementation of the

F4, F5 and G1 processes.

4.4.2 Programme costs

MOSL is tracking a total spend so far in this financial year of £1.404m against the approved

budget of £1.490m. The spend consists of £501k internal MOSL resource costs and £900K of

external costs associated with consultancy, design, software development and testing,

hosting and software licences.

4.4.3 Ongoing operations and support

The Bilateral Hub has become a Central System of the market which MOSL and its IT partner

are supporting as Trading Parties make requests for help and submit reports of bugs.

Following the implementation of the Bilateral Hub, MOSL is accessing a richer set of

performance indicators, which will continue as more processes are brought online. This is

likely to lead to more queries from Trading Parties about bespoke reports and provide an

opportunity for MOSL to carry out more market data analysis.

4.5 CMOS Impacts

4.5.1 Bilateral Hub and CMOS integration

The Bilateral Hub will not write information back to CMOS. Therefore, there is no direct

impact on CMOS from the Bilateral Hub in general, nor from the implementation of the F4,

F5, or G1 process.

Industry Engagement

Trading Parties are involved, engaged, and receive communications at regular stages

throughout the programme.

5.1 Advisory groups

There are four advisory groups made up of Trading Party experts. Further detail on the

make-up of the groups and any strategic discussions and challenges they raised as part of

this Change Proposal is set out in Appendix 1. Meeting minutes for each group are available

on MOSL's website here.

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5.2 Document distribution

The MOSL website has an area dedicated to the bilateral transactions programme,

containing plans and meeting documentation (e.g. agendas, slides, minutes, links to

recordings of meetings, etc).

There is also a ‘key documents’ area where up to date versions of all the most important

programme documents can be found, including links to previous versions where

appropriate.

Whenever new or updated documents are published on the MOSL website, Contract

Managers (or members of other mailing lists) are sent emails with links to the relevant

document(s). MOSL also intends to summarise the CPW070c suite of code amendments into

a single ‘Summary Pack’ which has proven helpful in the past to Trading Parties.

5.3 Contract Manager meetings

To ensure Contract Managers remain up to speed with the programme, MOSL hosts

monthly planning update meetings. The slides and a link to a recording of the session is

issued to all Contract Managers after each meeting.

5.4 One-to-ones

MOSL continues to host one-to-ones with Trading Parties as required, which offer updates

and technical support tailored to the individual Trading Party.

5.5 Training

MOSL has designed the Bilateral Hub to ensure minimal training is required. However, there

are resources to hand to help Trading Parties learn the system, including printed and short

video training materials.

5.6 Query management

To efficiently capture, prioritise and route Trading Party queries, the programme has

adopted a service desk-style ticketing system. Experience demonstrates that this is

particularly useful following a new process coming online.

5.7 Assurance and integration discussions

MOSL is retaining the successful approach to assurance testing from Phase 2 and has:

• Provided early sight of technical specifications and code documentation to enable

Trading Parties to develop integration on their side

• Offered technical ‘drop-in’ sessions, to give Trading Parties the opportunity to clarify

their understanding of transactional design and give MOSL the opportunity to flag

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upcoming changes and defects. These sessions have continued and will do so as we

approach the release for phase 3

The assurance process will follow a similar format as phase 2, but as part of the lessons

taken from the phase 2 release, MOSL will be looking to carry out a more proportional

exercise that considers previous assurances from previous phases. MOSL believes that

overall, this approach will still provide a robust level of assurance where Trading Parties

have sufficient opportunity to test systems for critical functionality.

The assurance exercise for phase 3 will consist of:

• An assurance testing exercise for Trading Parties to carry out where they have

developed their own integration with the Bilateral Hub. This will mean that Trading

Parties will be required to complete several test scenarios and provide evidence of

successful tests to demonstrate that their systems can communicate with the Bilateral

Hub effectively

• For Trading Parties that will be using the LVI, there will be a requirement to carry out a

short test scenario that demonstrates their understanding of the new functionality that

is being introduced, ensuring that there are no issues experienced in critical

functionality

• MOSL will continue to provide a pre-production test environment for Trading Parties to

develop and test against, which is updated regularly to ensure that Trading Parties have

access to the latest functionality early in the development cycle

• The observations and defects logging process will continue to help MOSL identify and

resolve unexpected behaviour in the Bilateral Hub as soon as users identify it.

As was the case with phase 2, MOSL will monitor and report on the progress made by

Trading Parties towards assurance and implementation. It will work closely with Trading

Parties that require more support than others and escalating any issues through the

programme governance where appropriate.

The next Trading Party ‘checkpoint’ survey is due to take place in February 2022 ahead of

the launch of phase 3 at the end of May.

5.8 Trading Party surveys

Where appropriate, MOSL carries out surveys with Trading Parties, either as an assurance

‘checkpoint’ to understand their readiness, or to ask specific questions to aid the

development of the Bilateral Hub, e.g. capability to manage concurrent users to ensure the

Bilateral Hub has sufficient capacity to cope with the anticipated demand.

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Following the launch of the Bilateral Hub and the first process in September 2021, MOSL

issued an optional survey asking Trading Parties for feedback on key aspects of the process,

e.g. launch, testing, programme delivery, etc.

Thirty Trading Parties responded to the survey, 23 Wholesalers, five Retailers and two NAVs.

Three companies also provided detailed responses offline.

The overall response was very positive, with 69% of respondents reporting that they were

either ‘satisfied’ or ‘very satisfied’. A further 26% were ‘neutral’. The scores were weighted

to neutral or better, with most of the highest scores in ‘satisfied’.

The highest scoring category was the Operational Advisory Group, which scored 81%

(satisfied and very satisfied), followed by ‘Launch’, which scored 71%. High level survey

results were published in MOSL’s November Market Focus newsletter.

One company expressed strong dissatisfaction with both programme delivery and the

programme overall. Following the survey results MOSL had a positive and productive

meeting to discuss the response and any lessons in more detail.

6 Panel Decision

6.1 Panel Recommendation to approve/reject

As this is the Draft Recommendation Report, this section will be completed following the

Panel’s decision in January 2022.

6.2 Objectives and Principles of the MAC and WRC

As this is the Draft Recommendation Report, this section will be completed following the

Panel’s decision in January 2022.

6.3 Recommendation

The Panel is invited to:

• AGREE to recommend the code amendments of CPW070c: Phase 3 – Bilateral

Transaction Programme

• AGREE to recommend an implementation date of 31 May 2022, if Ofwat approval is

received by 31 March 2022

• PROVIDE rationale as to whether the Change Proposal will or will not better facilitate

the MAC and WRC Objectives and Principles.

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Appendix 1: Advisory Groups

This appendix provides more information about the amount of contact time that the

programme has had with the advisory groups, what their membership is and some of the

key themes, feedback and challenges the groups have considered and fed back on.

Further detail, including the minutes of advisory group meetings are published on MOSL’s

website here.

Operational Advisory Group (OAG)

Rationale/purpose The Operational Advisory Group (OAG) was established in early 2020

and operates against a defined set of Terms of Reference, it is made

up of subject matter experts (SMEs) who engage with MOSL to test

assumptions around operational-related issues, such as Bilateral Hub

functionality, potential enhancements and process redesign.

OAG helped develop detailed B5 process steps that were not

originally detailed in the Operational Terms

Membership 25 regular OAG members and guests, 15 Trading Parties represented

(10 Wholesalers, 5 Retailers). Currently meet on a fortnightly basis.

Meetings Fortnightly. As of January 2022, the OAG has generated around a

thousand Trading Party contact hours with the Programme team.

Themes,

feedback, and

challenges

Key strategic considerations by the OAG in the hub and process

design:

1. MOSCOW analysis performed on F5 process to ensure

programme delivering MVP. Result is the F5 solution does not

contain a Site Visit Module which means recording the outcome

of a site visit on F5 works differently than C1 and B5. Some OAG

members felt this lack of consistency meant the hub wouldn’t

deliver as much efficiency as it could. MOSL noted that the F5

process as is in the code does not set out a site visit requirement

and it would become resource intensive to design all processes

with all modules, just in case, as MVP.

2. As the MOSCOW analysis meant there would not be a built-in

follow-on process, TPs would have to raise their own follow-on

process. As such, the OAG decided that F5 process should not

“auto-close” as this would remove visibility of the complaint that

underpinned the follow-on process.

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3. Wholesaler-initiated F4 and F5 processes should be permitted,

but not mandatory. There are still occasions where a Non-

Household Customer is better served by being referred by the

Wholesaler to the Retailer. This feedback was taken on board and

designed as proposed by OAG into the solution.

4. The creation of new Wholesaler-initiated processes allowed the

OAG to consider, and reconfirm, that its right by design that the

Bilateral Hub does not allow one Trading Party to raise a Request

on behalf of another. To do so would undermine Request

ownership and complicate SLA calculation and workflows. In

principle, if any future process reviews reveal that Wholesalers

have been raising service requests on behalf of their Retailers,

then a Wholesaler-initiated version of that process should be

investigated.

5. OAG discussed aligning the SLAs for F4 and F5 but decided

against it as it risked deprioritising the more serious complaints

process by putting unnecessary urgency on the less serious

enquiry process.

6. OAG noted a strong preference for TPs to manually record the

date of receipt of a complaint so that it would be acted upon

promptly and its lifecycle could be tracked beginning to end, pre-

dating the day it is raised as a Service Request. This feedback was

taken on board and designed as proposed by OAG into the

solution.

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Technology Advisory Group (TAG)

Code Advisory Group (CAG)

Rationale/

purpose

The Code Advisory Group is a formal sub-committee of the Panel and

operates to a defined set of Terms of Reference and reviews/assesses

proposed code amendments for each phase of the Change Proposals,

helping develop amendments and alternative drafting as necessary.

The Code Advisory Group has created, edited, and reviewed code

amendments for this Change Proposal.

Membership 7 regular CAG members, 7 Trading Parties represented (3 Wholesalers,

4 Retailers)

Meetings Fortnightly

Themes,

Feedback, and

challenges

Key strategic considerations by the CAG in the code design, based on

solution advice from subject matter experts, OAG, MOSL legal counsel

and Ofwat:

Rationale/purpose Operates to a defined set of Terms of Reference it helps to advise and

inform MOSL’s digital and data strategy and to understand the

practical ‘real world’ implications of its proposals on market

participants’ technology roadmaps.

Considers wider IT architecture and implementation challenges

relating to the bilateral transactions programme.

Membership 18 Trading Parties represented (10 Wholesalers, 8 Retailers).

Meetings Bi-monthly

Themes, feedback, and challenges

TAG considers approaches for implementation, certification,

assurance and testing and updates for technology and approval of

technical designs.

No fundamentally new technology themes have arisen as part of

CPW070c and therefore there has not been any challenges from the

TAG.

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1. Removal of T353.W transaction in favour of future proofed T224.W

transaction supported by CAG, but group challenged MOSL to

ensure that combined valid set for a key data item was fit for

purpose. Transaction sent back to OAG which confirmed a small

change to the valid set which was incorporated into the solution.

2. CAG clarified market code language to ensure that Trading Parties

would know that GSS rules were distinct from the F5 complaints

process, including where deferrals are used.

Pathfinder Group

Rationale/purpose Assembled later in the programme made up of a representative number of Trading Parties and third-party integrator subject matter experts who advise on MOSL’s implementation, assurance, and testing plans.

The group works with MOSL to review and challenge/support the teams’ ideas around implementation and to test release of new features.

The group also reviews and discusses known issues or challenges for

the programme team to seek guidance from the industry to ensure

correct decisions are made at critical points within the development

and implementation workstreams.

Membership 12 Trading Parties represented (6 Wholesalers, 4 Retailers) plus two

Third Party Integrators (TPIs)

Meetings Fortnightly

Themes,

feedback, and

challenges

The Pathfinder Group inputted on key programme activities and

decisions, including:

1. Key feedback on the programme plan and approach to phase 3

delivery timescales – A key focus for the Pathfinder Group has

been to input onto the phase 3 delivery plan and ensure that a

view across a variety of Trading Parties has been considered.

Pathfinders provided two key areas of feedback on the plan for

MOSL to consider:

a. Concerns around the speed of delivery for phase 3

processes – multiple parties asked MOSL to consider

that delivering multiple processes in a shorter

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timescale would be a challenge for Trading Parties.

This feedback was considered and factored into the

revised plan that was shared with parties in

December 2021 which saw the originally scheduled

31 March implementation date for B5 move later to

31 May.

b. Challenge on the delivery approach – Feedback from

the Pathfinder Group asked MOSL to consider the

approach to delivering multiple processes and

suggested there was benefit to releasing multiple

processes on a single release date into production to

allow Trading Parties to align their preparation and

resource to a single date. This was taken on board

and delivered in a revised delivery plan.

2. Feedback into the lessons learned exercise carried out after

the implementation of the phase 2 – Pathfinders fed back to

MOSL upon the completion of phase 2 and feedback was

provided in the following key areas:

a. Pathfinder members provided positive feedback on

MOSL communications in the run up to the go live for

phase 2 and asked that MOSL continued to provide

timely responses to support queries

b. Although member provided positive feedback on the

programme delivery for phase 2, concerns were

raised about increasing the speed of delivery while

moving into phase 3

3. Feedback on the descoping of email notifications

functionality – One of the key learnings for MOSL, following

the delivery of phase 2, was to ensure that the scope for

each process was clearly defined using a MOSCOW approach

and limited to ‘must have’ functionality as opposed to

including any ‘should have’ or ‘could have’ functionality.

Email notifications was defined as ‘should have’ functionality

and there was some LVI users that expressed the importance

of this functionality during the descoping discussion.

There are multiple discussions of this nature where Trading

Parties may suggest that certain functionality should be

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included within the Bilateral Hub. MOSL is working with

Trading Parties on to ensure that the delivery scope for each

process processes remains strict to ‘must have’ functionality

to ensure that there is not an increase in time or cost for the

programme. These conversations continue through many of

the stakeholder groups for the programme and for multiple

additional functionality requirements.

P63_03 CPW070c: Phase 3 - Bilateral Transactions DRR v1.0 31 January 2022 Page 25 of 27

Appendix 2: Code Documents amended for this change

No Code Document Hyperlinks to Documents

Clean Tracked Release Notes

1 Schedule 1, Part 3: Operational

Terms v1.0

id=1631 id=1630 id=1629

2 OSD 0703 Bilateral Processes

for Part B – Metering (B5)

v1.2.1

id=1596 id=1597 id=1598

3 OSD 0707 Bilateral Processes

for Part F – Monitoring,

investigations, complaints and

enquiries v0.3

id=1619 id=1618 N/A

4 OSD 0708 Bilateral Processes

for Part G – Trade Effluent v0.2

id=1622 id=1621 N/A

5 Annex F – Process Diagrams

v1.0

id=1443 id=1442 N/A

6 Annex G – Process Diagrams

v1.0

id=1445 id=1444 N/A

7 CSD 0002 Market Performance

Framework v1.3

id=1627 id=1626 id=1625

8 CSD 0302 Standing Reports and

Data Extracts v1.0

id=1624 id=1623 id=1636

9 CSD 0601 Bilateral Data

Catalogue v1.3.3

id=1585 id=1584 id=1583

10 Form F/01 Enquiries and record

of drinking water enquiries

withdrawn

(link to current live form)

N/A

11 Form F/02 Complaints and

record of drinking water

complaints and concerns

withdrawn

(link to current live form)

N/A

12 Form G/01 Trade effluent

enquiries

withdrawn

(link to current live form)

N/A

Notes: Version numbers refer to the draft versions of code documents within the CPW070c

change proposal, not to live versions of the code documents.

ID references refer to the names of the downloadable links. More detail on changes can be

found in the change log.

P63_03 CPW070c: Phase 3 - Bilateral Transactions DRR v1.0 31 January 2022 Page 26 of 27

Appendix 3: Customer journeys

The following are visual examples of customer journeys before and after this code change.

1. KPIs focus Trading Parties on reaching good customer outcomes.

2. Customers receive a prompt service from Wholesaler if they’re the first point of contact and aren’t passed from pillar to post.

Day 0

Customer complaint referred by Retailer to Wholesaler

Day 8Wholesaler determines complaint is

frivilous, does not provide substantive answer but satisfies OPS. Loose (or no) indication provided as to whether more

concrete reply or reconsideration will follow. The Request is completed.

Day 10

Retailer engages customer who is aggrieved that Wholesaler has not

replied and there is service standard that can compel them to do so. Complaint has to be raised

anew.

Day 0

Customer complaint referred by Retailer Wholesaler

Day 8

Wholesaler determines they cannot answer the complaint, but must use one of

recognised deferral reasons if they need more time, and deferral period is time

limited. Request is still live and OPS is still outstanding.

Day 10

Retailer engages customer who is aggrieved that Wholesaler has not

replied. However, live Requeset and active OPS gives retailer something they can monitor and use to compel

a Wholesaler reply.

Day 0

Customer writes a complaint to the Wholesaler which the Wholesaler feels they can and should progress

quickly but codes do not allow.

Day 5

Customer is told by the Wholesaler days later they should write to their retailer (there is no

SLA).

Day 6-8

Customer writes to retailer, is told the matter is Wholesaler related.

Customer is aggrieved that they've being sent right back where they

started and is left with poor impression of the market.

Day 0

Customer writes a complaint to the Wholesaler which the Wholesaler feels they can and should progress

quickly which codes allow.

Day 1

Wholesaler has registered the Request in the Bilateral Hub . Thought they are the

originator, the Retailer gets Bilateral Hub notification.

Day 6-8

Wholesaler has crafted reply to the customer with time left to collaborate

with Retailer to see if they have additional information to provide in

support.

To be: There is always a live service request and outstanding OPS until a substantive reply is provided.

As is: Wholesaler not always compelled to provide a substantive response which lengthens resolution time.

To be: Wholesaler starts investigated the complaint and crafting the reply immediately and Retailer is

given full visibility that their customer has gone to the Wholesaler.

As is: Wholesaler refers complaint to the retailer if approached directly by customer even if able to address it.

Alternatively, they progress complaint in contravention of code-defined processes and possibly raise a service request

on behalf of the retailer (which retailer may or may not know about).

P63_03 CPW070c: Phase 3 - Bilateral Transactions DRR v1.0 31 January 2022 Page 27 of 27

3. Enquiries, complaints and Trade Effluent Complaint can be monitored and reported on where follow-on activity is needed.

4. Submission of Requests is quicker, and Rejections are reduced as key enquiry and complaint information is validated by the Hub

Day 10

F4, F5 or G1 process actioned by Wholesaler. Further "desk research"

needed but this could take a few weeks. The service request is closed.

Day 11

There is no bilateral visibility of of the F4, F5, or G1 request needing a follow-up. Easy for

both Retailer and Wholesaler to lose track of any follow-on work, or link it to a particular

Bilateral Request.

Day 20

Customer contacts retailer for update. Speaks to new agent at

Retailer who can't easily confirm customer's position that

outstanding work was pledged following their F4, F5, or G1 Request. Confusion caused.

Day 0

F4, F5 or G1 process actioned by Wholesaler. Further "desk research"

needed but this could take a few weeks. The service request is closed

Day 11

The completion transaction records that a FOLLOWON, (or NOFOLLOWON) is needed for the Request. Forms part of the data set

which could be used for a variety of monitoring/reporting applications from the

Hub.

Day 20

Customers contacts Retailer for update. New agent at Retailer can confirm there was a committment when Request closed. Combined with ORID linking functionality of the Hub, the Retailer can tell the

customer what happened as result of their F4, F5 or G1 Request.

Day 0

Customer raises an enquiry which the Retailer relays to the

Wholesaler

Day 10 (SLA to reply to enquiries)

Wholesaler rejects the Request as incomplete or incorrect customer premise

data included on the form.

Day 11

Customer contacts retailer, is told matter must be raised anew

because the form didn't have the right information on it. Customer is

where they started and has poor perception of the market.

Day 0

Customer raises an enquiry which the Retailer relays to the

Wholesaler

Day 10

Validation of key information like the SPID and fulsome customer contact details

provided to the Hub reduces risk of rejection and the Wholesaler has a better

ability to respond appropriately.

Day 11

Customer contacts retailer with greater likelihood of getting an appropriate answer on time. If Wholesaler cannot accept the

Request a formal resubmission step eliminates need to end Request and start from scratch which is quicker.

To be: F4, F5, and G1 Requests which need a Follow-on are clearly indicated within the hub through

dedicated Data Item which could be monitored, reported through Bilateral Hub.

To be: A standard LVI interface and standardised submission and acceptance transaction (for HVI users)

reduces the risk that inadequate information is passed between Trading Parties.

As is: When customer details and other key information is not materially completed, this can lead to rejected Requests

and delays to customer outcomes.

As is: Ability to determine if F4, F5, and G1 Request is completed with Wholesaler follow-on work has to be monitored

separately from the Request