January 22, 2018 Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, Michigan 48917 RE: In the matter, on the Commission’s own motion, to require DTE Electric Company and DTE Gas Company to investigate and to submit a report to the Commission Staff regarding each utility’s billing practices MPSC Case No: U-18486 Dear Ms. Kale: Attached for electronic filing is the DTE Electric Company’s and DTE Gas Company’s Report in compliance with Commission’s Order of December 20, 2017 in the above matter. Very truly yours, David S. Maquera DSM/lah Encl. DTE Energy Company One Energy Plaza, 688 WCB Detroit, MI 48226-1279 David S. Maquera (313) 235-3724 [email protected]m
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U-18486 DTE Electric and DTE Gas Report on Billing Practices
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January 22, 2018
Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, Michigan 48917
RE: In the matter, on the Commission’s own motion, to require DTE
Electric Company and DTE Gas Company to investigate and to submit a report to the Commission Staff regarding each utility’s billing practices MPSC Case No: U-18486
Dear Ms. Kale:
Attached for electronic filing is the DTE Electric Company’s and DTE Gas Company’s Report in compliance with Commission’s Order of December 20, 2017 in the above matter.
Very truly yours,
David S. Maquera DSM/lah Encl.
DTE Energy CompanyOne Energy Plaza, 688 WCB Detroit, MI 48226-1279
Introduction DTE Energy (“DTE” or the “Company”)1 lives by its seven core values, which includes: “We see our work through the eyes of those we serve… and know that our work is powerful means to serve others.” Accordingly, DTE uses the lens of its values in the decision making of the development, implementation, and processes used to serve its communities to provide safe, reliable, affordable, and sustainable electric and gas service. In April 2017, DTE transitioned to a SAP technology platform referred to as Customer 360 (“C360”). This customer relationship and billing platform represents one of the most significant technology upgrades in the Company’s 150-year history. C360 streamlines 130 separate end-of-life software systems into one comprehensive platform. DTE contracted hundreds of customer service representatives and spent five years planning for the transition to C360 to maintain the Company’s high standards of service. Notwithstanding DTE’s preparations and its comparatively successful implementation, DTE recognizes that in the process of transitioning 3.4 million customers to a brand-new platform that some customers experienced billing issues. These issues have impacted the quality of customers’ service including wrongful service disconnections due to C360 billing defects. DTE is committed to making this right. On December 20, 2017, the Michigan Public Service Commission (“MPSC” or the “Commission”) issued an Order in MPSC Case No. U-18486 requiring DTE Electric Company and DTE Gas Company to investigate and submit a report addressing concerns related to each utility’s billing practices. Specifically, the Commission required the report to:
1. Provide DTE’s performance history regarding shutoffs from January 1, 2016 through the present, highlighting the transition period for C360, provide the number of customers shut off by each month and, in the interim, continue to report weekly shut off numbers to the Staff.
2. For the time period prior to the implementation of C360, provide DTE’s typical error rate for wrongful disconnection and any information DTE has on the industry standard.
3. Provide an explanation of the verification process DTE performs prior to disconnecting a customer.
4. Provide an explanation of the impact of C360 on shutoffs since the implementation, including details on the type of defects, identifying when defects were fixed, and the number of customers impacted by month by each defect.
5. Review with the Staff a list of customers who were improperly shut off, reason for shutoff (i.e.: C360 no bill, C360 bill presentation, AMI scheduling and MPSC open informal
1 Both DTE Electric Company and DTE Gas Company are wholly-owned subsidiaries of DTE Energy.
4
complaint, etc.), restoration length of time from disconnect, and any remedy provided to customer.
6. Outline DTE’s customer communication efforts regarding shutoffs with details that include how and what information was communicated to customers who had been improperly shut off.
7. Provide an explanation of DTE’s plans going forward to address all improper shutoffs. As directed by the Commission, DTE submits this Report providing the Company’s performance history related to shutoff and billing practices as well as detailing our plan and commitment to zero cuts in error.
5
1. Shutoffs History 2016 and 2017 Provide DTE’s performance history regarding shutoffs from January 1, 2016 through the present, highlighting the transition period for C360, provide the number of customers shut off by each month and, in the interim, continue to report weekly shut off numbers to the Staff. There are four (4) distinct scenarios/processes where DTE would initiate a shutoff of services (discontinuance of utility service that is not requested by a customer).
In March of 2017 we began our C360 transition and discontinued collection activities and customer shutoffs. We resumed collection activities in mid-May of 2017.
a) Customers physically discontinued due to non-payment: 243,504 shutoffs in 2016 and 153,889 in 2017
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b) Customers physically discontinued due to customer denying DTE access to the Company’s
equipment to switch their analog meters to AMI (Advanced Metering Infrastructure): 34 shutoffs in 2016 and 653 in 2017
c) Customers physically discontinued due to customer denying DTE access to the Company’s equipment to move inside meters outside as part of the MMO/MRP programs (Meter Move Out/ Main Renewal Programs): 552 shutoffs in 2016 and 112 in 2017
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d) Customers physically discontinued due to unauthorized use of utility service: 44,495 shutoffs in 2016 and 9,796 in 2017
Going forward, we will continue to provide customer shutoff data to the MPSC Staff at our weekly check in meetings. 2. Wrongful Disconnection Error Rate For the time period prior to the implementation of C360, provide DTE’s typical error rate for wrongful disconnection and any information DTE has on the industry standard.
2016 wrongful disconnection error rate: 0.12% DTE’s typical error rate for wrongful disconnection is based on billing and noticing issues. In 2016, there were a total of 295 wrongful disconnections. Based on the total of 243,504 total customers physically discontinued due to non-payment in 2016, this represents a very small fraction of our customers (0.12% error rate). C360 wrongful disconnection error rate: 0.26% During the eight (8) months period following the April 2017 C360 implementation from May through December 2017, there were a total of 252 wrongful disconnections out of a total of 101,745 customers physically discontinued due to non-payment and a total of 18 wrongful disconnections out of a total of 653 customers physically discontinued due to denied access to switch the analog meter to AMI. No customers have been erroneously disconnected due the MMO/MRP project and due to the unauthorized use. Industry standard wrongful disconnection error rate: 0.25%-0.65% Accenture informal survey process of North America utility companies of relative size, composition and complexity as DTE show an average error rate for wrongful disconnection ranged from 0.25% to 0.65%. Due to the sensitive nature of the information requested as well as the informal data collection procedure, the participating utility companies have chosen to remain anonymous. The letter from Accenture has been included as Attachment 1.
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3. Verification Process Prior to Shutoff
Provide an explanation of the verification process DTE performs prior to disconnecting a customer. a) Customers physically discontinued due to non-payment A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 2.
The process map that DTE follows for the Collection of Residential Accounts is included as Attachment 2. This process is designed to ensure that we strictly follow the guidelines that we have set in place for the billing, notification, collection, and disconnection of our Residential Customer Accounts. This process is robustly designed to create a set of checks and balances to provide every opportunity for our customers to avoid an interruption of their utility service. This process is also designed to give DTE an opportunity at many steps in the process to ensure that only customers who have not met the required obligations to DTE continue through to the next steps of the collection process. While we have found that a small number of errors have occurred in this process recently, the appropriate changes have been made to prevent those same errors from occurring in the future. These changes include: 1) the development of built-in rules and embedded tests that allow customers to advance through the collection flow and service orders to be sent to the field for disconnection; 2) a disconnection audit report, developed late 2017 and implemented in January 2018 that will perform additional checks and flag potential wrongful shutoffs to be manually reviewed. This process is designed to mitigate any improper service interruption for our customers and to ensure compliance with the MPSC’s billing practices. b) Customers physically discontinued due to denied DTE access to switch their analog meters to
AMI A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 3.
Given the significant impact of cuts to DTE’s residential and commercial customers, the Company takes the process under which the AMI-related cuts are executed very seriously. In particular, the Company’s goals with this process are that it is followed consistently in every instance and that it also eliminates any potential errors via various checks along the way. This is accomplished by the development of and adherence to a detailed process map (see Attachment 3), which was designed with clear lines of responsibility. In addition, there are a number of embedded tests built into the process with the intent to highlight any anomalies so as to avoid any AMI-related cuts in error. Where some of these cuts in error have occurred in late 2017, the process map was modified accordingly in order to prevent such instances from occurring in the future. This process map has been rolled out to the various process owners within the process and it is posted in many locations to ensure that everyone is clearly aware of the expectations.
9
c) Customers physically discontinued due MMO/MRP project (Meter Move Out/ Main Renewal Program)
A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 4. No customers have been erroneously disconnected in this process during the period under review. d) Customers physically discontinued due to unauthorized use of utility service A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 5. No customers have been erroneously disconnected in this process during the period under review.
4. C360 System Impact on Shutoffs
Provide an explanation of the impact of C360 on shutoffs since the implementation, including details on the type of defects, identifying when defects were fixed, and the number of customers impacted by month by each defect. Below is a list of the C360 system defects that affected collection processes and potentially caused a wrongful disconnection, including the number of customers impacted by month:
5. Wrongful Disconnections
Review with the Staff a list of customers who were improperly shut off, reason for shutoff (i.e.: C360 no bill, C360 bill presentation, AMI scheduling and MPSC open informal complaint, etc.), restoration length of time from disconnect, and any remedy provided to customer.
C360 System Defect Description Fix date Jun Jul Aug Sep Oct Nov Dec Total
Disconnection Workflow not cancelled on reconnection order 6/12/2017 4 0 0 0 0 0 0 4
Customer incorrectly disconnected with Flag for Red Bill in Waiting
print status6/16/2017 21 0 0 0 0 0 0 21
Payments incorrectly accepted when collection cut order is in
Unprinted invoices not excluded from the collection process 10/6/2017 1 4 3 1 1 0 0 10
Incorrect shut off date when Subsequent Red Bill reached before
Flag for Red Bill is printed10/27/2017 5 51 21 5 1 0 0 83
Incorrect shut off date on Red Bill 12/8/2017 3 39 27 23 2 1 0 95
Total 39 121 58 29 4 1 0 252
Number of customers wrongfully shutoff
10
DTE personnel met with Staff on Tuesday, January 16, 2018 and Friday, January 19, 2018 to review the list of customers who were improperly shut off, reason for shutoff, restoration length of time from disconnect and remedy provided to the customer. 6. Shutoff communication efforts Outline DTE’s customer communication efforts regarding shutoffs with details that include how and what information was communicated to customers who had been improperly shut off. No communication was completed after the wrongful disconnections took place, except the restoration interactions. Once improper shutoffs were identified restore events were escalated and processed same day.
7. DTE Energy Plans Going Forward An explanation of DTE’s plans going forward to address all improper shutoffs. The new C360 system has built-in rules and embedded tests that allow customers to advance through the collection flow and service orders to be sent to the field for disconnection. Additionally, as a double check, a disconnection audit report was developed late 2017 and implemented in January 2018. This report will perform additional checks and flag potential wrongful shutoffs, cancelling the disconnect service order. Manual reviews will also be performed to prevent wrongful shutoffs in the future. Conclusion Utility billing and shutoff processes are established and enforced by MPSC. DTE adheres to these billing rules and utilizes a strict internal process for recognizing non-payment, notifying customers of intent to disconnect at several junctures, and ultimately disconnecting service. Defects in the new C360 billing platform did disrupt our normal billing processes and resulted in isolated incidents of wrongful disconnections. In these cases, customers either did not receive a bill or did not get correct notification of the shutoff process, but were still disconnected. The majority of these disconnections have been restored to normal service and most were restored on the same day. DTE recognizes the impact of the service interruptions and understands that this is a serious inconvenience for its affected customers. DTE’s customer service teams are working diligently to correct any outstanding billing issues resulting from the C360 transition. The disconnect process has been error-proofed by implementing measures such as a manual process for double-checking accounts flagged for disconnect by the software. These checks will ultimately be automated to ensure defects of this type are eliminated.
Accenture LLP
140 Fountain Pkwy N
Suite 400
St. Petersburg, FL 33716
www.accenture.com
January 15, 2018 DTE Energy 1 Energy Plaza Detroit, MI Re: Disconnect (for NonPay) in Error To Whom It May Concern: DTE Energy asked Accenture to research the industry-wide best practices benchmarking around the “Disconnect in Error” and/or “Disconnect Without Proper Notification” metric. Accenture ran an informal survey process to query top North America utility companies of relative size, composition and complexity as DTE Energy. Based on this informal process, we saw that the average “Disconnect in Error” metric ranged from .25% to .65% with varying degrees of inclusions/exclusions from the rule. Due to the sensitive nature of the information requested as well as the informal data collection procedure, the participating utility companies have chosen to remain anonymous. Sincerely, Dondi Schneider Managing Director North America Utilities SAP Lead Accenture
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 1 Page: 1 of 1
Process Collections for Residential Accounts
SA
P C
R&
BS
enio
r A
nal
yst
Cus
tom
er S
ervi
ce
Bu
sin
ess
Su
pp
ort
IT
Reminder Call Sent to collection
agency – Robo/Live callNotice of intent letter
sentRed shutoff bill statement sent
Day 25 Day 27 Day 30 Day 40
Start
Day 21
Red shutoff bill Due
Day 44
Create disconnect document
Day 45
Invoice is sent Invoice is due
Day 1
Is the customer past due balance
<$100
No
End
Yes
Is the customer past due balance
<$100
Is the customer past due balance
<$100
Is the customer past due balance <$100
Is the customer past due balance
<$100
Is the customer past due balance
<$100
End End End End End
Yes Yes Yes Yes Yes
No No
No No No
Create disconnect report
Is the customer past due balance
<$100
Yes
Reset dunning step to remove from
disconnect statusEnd
NoIs there 10 days between the
shutoff date and red shutoff bill statement print date?
Yes
Reset dunning step to remove from
disconnect status
No
End
End
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 2 Page: 1 of 2
Process Non-Pay Disconnects
SA
P C
R&
BF
SA
/OP
A/S
ervi
ce S
uit
e/A
MI
Create Disconnect Document
Create Order (Electric and Gas)
Response Received
Interface
Reschedule Next Business Day (Expiry
Date in Future)
Order Assignment + Schedule for Disconnect
Worked? Complete?Yes
No
No
Yes Combo Customer? YesOnly One Service
Off?
No
No
Yes
Reschedule for +7 Days
Perform Non-Pay Move Out
(+7)
End
Manual scheduling by workload
Interface
Day 45Day 46
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 2 Page: 2 of 2
AMI Cut Process
RM
&P
Fie
ld a
nd
Off
ice
AM
I Ins
talla
tio
ns
Elec
tric
Fie
ld
Ope
rati
on
s (E
FO)
Ove
rhea
d an
d
Un
der
grou
nd
Met
eri
ng
and
B
illin
g
Mai l Cordial Letter with
$50 Incentive to Customer
First Cut Letter sent to
Customer with $50 Incentive
Customer Respond in 7
Days?
Customer Respond in 7
Days?
Second Cut Letter Sent 5 Prior Days to Executing Cut
Customer Respond?
AMI Sends Cut List to RM&P to
Schedule Cut
Receives Cut List from AMI
Crew Executes Cut
Customer Accepts AMI or OPT Out
Meter?
Crew Leaves Notice at Site to Call RM&P for
Restoration Along with Safety Notice
Coordinates with Lines and EFO to Form Super Crew
EFO Installs Meter
Customer Cal ls RM&P for Restore?
Service Remains Off
YES
System Updates with Install information
Order Sent to EFO for AMI or OPT Meter Install
YES
Meter Installed and Refer order to OH/UG
Lines
Field Completes Restore within 2 Days of Receipt
YES
Analyze Account for
Meter Change
Verify account is Eligible for
Cut
Hold on Customer account?
Analyze Accounts and establish final
cut list
List Sent to Customer
Strategy for Dunning hold
NO
Account Held >24 hours?
Super Crew Arrives at Site for Install or
Cut NO
NO
YES
Customer Present?
END
AMI Meter Visible?
YES
AMI Team Verified AMI Meter Exist?
NO NO
Escalate or Restore
YES
Service Cut in Error?
Analyze Accounts for
multiple install at tempts
Notify Marketing &
Reg Rel of Cut Locations
NOMeter
Installed?
YESYES
END
NO
ET – Billing Informs AMI that Orders from Completion List have been Processed in CR&B and any SO25's have been worked
All Countermeasures are Highlighted in Yellow
Was Letter Returned?
Research Address and re-mail letter
YES
Was Letter Returned?
Research Address and re-mail letter
Init iate AMI Appointment
Process
Init iate AMI Appointment
Process
Init iate AMI Appointment
Process
Yes
NO
Sent to AMI Team: Dunning, Senior, Customer in Complaint
Process, Medical Alert
Account Removed from
Cut List
Verify Cut Order Still Valid
YES
Return to AMI Installation
NO
NO
END
YES
YES
Does order exist from another
Channel?NO
Perform Wellness Check
NO
YES
YES
NO
System Updates with Install information
Bill Issued to Customer?Reconcile Billing
NO
EndYes
NO
Was Letter Returned?
Research Address and re-mail letter
YES
NONONONO
Investigate Order Creation
YES
Updated: 1/12/18 v.6
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 3 Page: 1 of 1
Printed documents are considered uncontrolled. Verify current version prior to using.
True North: All (100%) impacted customers notified prior to DTE arrival.
Ass
et
Ma
nage
men
t O
pera
tions
A
nal
yst
MM
O /
MR
P C
onst
ruct
ion
Ope
ratio
ns A
naly
stC
rew
Lea
der
MM
O C
rew
Phase 3Phase 1 Phase 2
12Process Outputs:
Description: This is the process and the escalation for notifying customers impacted by the Gas Renewal Program.
Process Owner: Nachell GregoryLast Updated: 01/12/2018Review Cadence: Quarterly
TITLE: GRP Customer Communication and Letter Escalation Process Map
Metrics: Customers notified accordingly and timely.
Annotation Box
Decision ActivityStart/End Escalation
Out going to another
page
Incoming from
another page
Process Legend: ‐ Displays the desired path ‐ Escalation connection ‐ Connection‐ On page ConnecterX
Activity using
Document
Data Base
DataSub Process
Value Analysis Coding:
Waste
Not value added but necessary
Value Added
ET
Submit Mail Request for Program Letter
to impacted customers.
(30 days prior to Constructionl)
Make customer contact & schedule
appointment
Appointment Successful?
Attempt to make appointment with
Customer
Appointment Successful? (Repeat min. of three
times)
No
Crew completes Meter Move Out.
Yes
Appointment Successful?
Wait Ten Calendar Days
Yes
Appointment Successful?
Yes
Call Customer phone number(s) in C360 24 hours
Prior to service cut and cap.
Document C360 that call was made
to customer.
No
Customer Contact made
& Work Scheduled?
Yes
Cut and Cap service.
No
Yes
No
Update Customer Acct in C360 Final
Notice was left.
Scouting Letters Mailed to Impacted Customers
Program Letters Mailed to Impacted Customers
End
3 Door Hangers Left with Impacted Customers
Restoration complete?
Restoration Care Door Hanger Left
Restoration Season Door Hanger Left
Yes
No
Scout Assigned Location
Leave 10-Day Final Notice
(Notice of Gas Service
Interruption)
No
Leave “Sorry We Missed You“ Door
hanger
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 4 Page: 1 of 1
Theft Process V1
BPE
M C
ase
Bu
sin
ess
Un
itSe
rvic
e O
rder
Serv
ice
Suit
e
Author: Jampana
RAT Call/CR Thermal Imaging Detectant/TDIID Fraud AMI TheftTheft Internal ProspectingCorporate Security/
Compliance
Mtr Reads, EFO/GFO, Coll Reps,
DO
R728 R723 R745
R961 R959 R976
More Than 30 days old ?
CloseYes
R730
Customer Request?
R768(RAT)
R732(Thermal Imaging)
R734(ID Fraud)
R976
R735(AMI)
R758(Theft Escaltion)
Yes
R730(Theft Internal)
NO
R753(Prospecting)
Theft Work Order
R738(Corporate Security)
1To Page 2
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 5 Page: 1 of 3
Theft Process V1
Serv
ice
Ord
er
Serv
ice
Suit
eB
PEM
Cas
e(T
hef
t B
illin
g)M
axim
o
Serv
ice
Suit
e
Author: Jampana
Theft Work Order
Internal Theft Billing
N108
Generate R733/R371 Pole cut for electric or R370 for Gas
Generate R736 – Apt BldgNo action unless refer to cut is
Y
Moveout Customer, Update meter end date, update Disc reason to Theft, Update Site Level Security Block, Create
Interaction Record
Update Meter status to
Disconnected.(Will be turn on for other
account/BP)
Moveout Customer, Update meter end date, update Disc reason to Theft, Update Site Level Security Block, Create
Interaction Record
Update meter status to S-SealedUpdate Disc Reason to Theft
Update Site Level Security BlockCreate Interaction Record
Refered to Cut?
Referral
End
NOElectric/
GasYes
Service Order – MAT Code R733/R744(Pole Cut)
Electric
Active/InActiveGAS
Service Order – MAT Code R370(Maximo)
Active
Meter Exists?
InActive
Service Order – MAT Code R276(Maximo)
Yes
Unmeter Observed?code = 95??
NO
Service Order – MAT Code R272(Maximo)
Service Order – MAT Code R274(Maximo)
Yes
NO
Maximo Theft Work Order
CUT_CAP
NOCUT
LOCK_METER
CUT_REMOVE
METER_REMOVE
Update Service StatusInteraction Record
No ActionClose Service Order
End
End
01 – No Cut
55 – Pole Cut
30 –Theft Drip Cut
99 – Theft Removed Drop
Theft Work OrderSecured Completion Code(Service Level)
2To Service
Suite
3To Maximo
2From Service
Order(Referrel)
3From Service Order(Referr
el)
1From Page 1
Service Disconnected
Service Disconnected
Service Disconnected
10 Disconnect Meter20 – Meter Removed/
Meter moved check is X50 – Steal Remove60 – Turn on Taken95 – Unable to Secure
30 – No Theft/No action
98 –Refer to Apt Bldg investigation
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report
Attachment 5 Page: 2 of 3
Theft Process V1
BP
EM
Cas
eB
usi
nes
s U
nit
Serv
ice
Ord
erSe
rvic
e Su
ite
Max
imo
Author: Jampana
RAT Call/CRThermal Imaging
Detectant/TDIID Fraud AMI TheftTheft Internal ProspectingCorporate Security
Mtr Reads, EFO/GFO, Coll
Reps, DO
R728 R723 RXXX
R961 R959 R976
More Than 30 days old ?
CloseYes
R730
Customer Request?
R768(RAT)
R732(Thermal Imaging)
R734(ID Fraud)
R735(AMI)
R758(Theft
Escaltion)
Yes
R730(Theft Internal)
NO
R753(Prospecting)
Service Suite Theft Work
Order
R738(Corporate Security)
Disconnect Complete OR Referrel?
Service Suite
New ReferrelMaximo/Service Suite
Referrel
MaximoTheft Work
Order
Maximo
Internal Theft Billing
108
Disconnect Completed/Theft Found and requires Billing
Create new Service Order
MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report