Peco Medical Form – Fill Out and Use This PDF

BEFORE THE

PENNSYVLANIA PUBLIC UTILITY COMMISSION

PECO Energy Company Comments

On

The Commission's January 15, 2015 Tentative Order

On December 22, 2014, a new version of Chapter 14 of the Public Utility Code (66 Pa. C.S. §§ 1401-

1419), became law. On January 15, 2015, the Commission issued a Tentative Order requesting

comments on three issues related to implementation of the new law. PECO Energy Company ("PECO")

is pleased to provide the following comments.

1. Form of medical certificate

On pages 3-5 of the Tentative Order, the Commission requests comments on various issues

related to the "form of medical certificate" that will be utilized under the new law. PECO provides the

following comments.

First, PECO agrees that the new law has added two new elements to the existing definition of a

medical certificate: (a) It must be "in a form approved by the Commission;" and (b) Physician's assistants

may now sign a medical certificate.

The "Physician's assistant" requirement is the only change that affects the information required

in a medical certificate. PECO therefore respectfully suggests that existing medical certificates, with the

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minor change of allowing signature by a physician's assistant, will fully implement the substantive

changes to the definition of a medical certificate.

PECO has altered its existing medical certificate to allow signature by a physician's assistant. A

copy is attached. PECO respectfully notes that this form, or one like it, meets the definition of a medical

certificate - and has the substantial advantage of familiarity, for both PECO and health providers in its

service territory. PECO therefore suggests that this form of medical certificate meets the requirements

of the new definition of Chapter 56.

On page 4 of the Tentative Order, the Commission requests comment on whether utilities

should accept letters from medical doctors, etc., in lieu of the utility's form of medical certificate. Any

such letter would have to contain all of the information required by the regulations, or it would not

constitute a valid medical certificate under the regulations. The required information is already outlined

in the utility medical certificate form in easy-to-fill-in format. PECO cannot see any advantage to

allowing medical certificates to come in the form of separate letters, which will inevitably - not in every

case, but to some degree - leave out some of the required data. Since the data must be included,

whether it is the form developed by a utility or otherwise, there is no burden on the physician's office in

requiring it to use the utility form, rather than a separate letter. PECO therefore respectfully suggests

that utilities should only be required to accept medical certificates that are on the form developed by

them and approved by the Commission.

2. Reporting of Medical Certificate Data

On pages 9-10 of the Tentative Order, the Commission requests comment on a six-point

proposal regarding reporting medical certificate data. Below, PECO restates each point of the

Commission's proposal, then provides comments on it.

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Med Cert Reporting Proposal Point 1: At the conclusion of each calendar year, the utility shall count the number of medical certificates offered and/or accepted for the previous 12 months.

Med Cert Reporting Proposal Point 2: At the conclusion of each calendar year, the utility shall count the number of accounts that had a medical certificate offered and/or accepted for the previous 12 months.

PECO Comment on Points 1 and 2: The language of Chapter 14 speaks of certificates that are

"submitted and accepted," not "offered and accepted." New Section 1410.1(4) states:

(4)The public utility shall report to the commission on an annual basis the number of medical certificates and renewals submitted and accepted in the service territory.

PECO believes that the phrase "submitted and accepted" should be read as "submitted by

customers" and "accepted by the utility." The process, at least as currently followed by PECO, typically

follows this chronology:

•A customer calls PECO, verbally state the existence of a medical condition and submits a

request for a medical certificate.

•PECO accepts that verbal claim and suspends termination activity for three days to allow the

customer to obtain a written medical certificate from their physician's office.

•For many customer - often over 50% of those who submit a verbal request -- no written

medical certificate is ever submitted. In those cases, after three days PECO lifts the

termination stay.

•For the remaining customers, a written medical certificate is submitted by the customer.

•PECO then evaluates the certificate for completeness and authenticity. If it meets standards

in both of those areas, PECO accepts the written medical certificate and suspends

termination for 30 days. If the certificate fails in one or both of those areas, PECO rejects it.

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3. $10,000 Arrearage Reporting

On pages 5-9 of the Tentative Order, the Commission requests comment on a seven-point proposal

regarding reporting medical certificate data. Below, PECO restates each point of the Commission's

proposal, then provides comments on it.

Arrearage Reporting Proposal Point 1: Utilities shall examine all of their residential accounts (a "snapshot") at the conclusion of each calendar year. Any account with an arrearage at or exceeding $10,000 at that time shall be reported to the Commission by March 1 of the following year.

Arrearage Reporting Proposal Point 4: Reporting should begin, under these interim guidelines, with calendar year 2015 -the first annual report would be due to the Commission by March 1, 2016.

Arrearage Reporting Proposal Point 6: Reports shall be filed with the Commission's Secretary under the docket number for this order. An electronic courtesy copy shall be provided to the Director of the Bureau of Consumer Services at the same time.

PECO Comments on Points 1, 4 and 6: PECO agrees that a single annual filing date is appropriate, and

that a "snapshot" of data as of year-end is appropriate. Filing dates at the end of calendar quarters tend

to coordinate better with normal data collection activities, and PECO therefore suggests March 31,

rather than March 1, as an appropriate filing date. PECO also suggests that the data filed on March 31,

should be for the trailing calendar year ending on December 31. With the medical certificate reporting,

PECO suggested that the medical certificate data reporting should be incorporated into the ongoing

Section 231 data reporting, rather being filed directly in this docket. For the arrearage reporting,

however, PECO agrees that the complexity of the probable data points warrants a separate filing for the

arrearage data in this docket. Notwithstanding that, the timing of the two data reporting efforts should

be coordinated.

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Arrearage Reporting Proposal Point 2: Each account reported should be identified to the Commission with a unique label that the utility can match to the account in question. Customer names, addresses, account numbers or other information that could be used to identify the customer shall not be included.

PECO Comments on Point 2:

PECO agrees that customer privacy will be protected by the use of unique labels that can be matched to

the account in question, but which do not identify the account. PECO requests that the Commission

allow utilities latitude to use unique labelling systems that coordinate best with their IT systems.

Development of such unique labeling systems cannot be pursued until all data collection issues are

resolved (see below), and therefore are likely to be one of the last issues resolved as utilities work

toward final reporting protocols.

Arrearage Reporting Proposal Point 3: The information concerning each of the accounts shall include: account balance as of the time of the "snapshot" and the time period over which that arrearage accrued (in years or months). For that time period, the average monthly bill amount; number of Commission informal or formal complaints; and the number of company payment arrangements.

PECO Comments on Point 3:

•Account balance as of the time of the snapshot: PECO agrees that this is a reasonable reporting metric that acts as a gate to whether the account should be included in the report.

•The time period over which the arrearage accrued: In PECO's experience, high delinquency accounts typically start to develop delinquencies very quickly upon opening. When that is not the case, it can be very difficult to determine "when" the arrearage accrued, short of a manual inspection of the history of the account to determine the last time, if ever, that the account had a $0 balance. PECO therefore recommends that this data point simply be the time that the account has been opened. With that said, even that can be somewhat misleading, because an account may be open only a few months - but have an arrearage transferred to it from the customer's prior address. This would make it appear that the customer account has been open only a short period of time, but has a high balance, when in fact the arrearage accumulated over a longer period of time. PECO does not have any method within its IT systems to "untangle" this issue on a systematic basis.

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•Average bill: For the reasons noted above, PECO suggests reporting the average bill only for the last 12 months of service, based on the budget bill amount for those customers on budget billing, and the 12 month trailing average for other customers.

•Number of Commission formal and informal complaints: PECO agrees that this is an important data point. Indeed, in PECO's experience, some customers use the formal and informal complaint system as method to avoid termination and accumulate high balances. To address that concern, PECO respectfully suggests that the Commission should evaluate a possible Commission initiative to accelerate the resolution of all informal or formal residential complaint matters with high arrearages. One approach might be for the utility to identify any complaint that involves an account with a balance of $7500 or more, or which includes a high balance complaint, and have that account placed into accelerated treatment. PECO is happy to work with the Commission on a pilot program in this area.

•Number of payment arrangements: Again, PECO agrees that this is an important data point.

•Landlord status: Once arrearages are accrued in a landlord/tenant situation, there are very few tools available to reduce the arrearages. Landlord arrearages, even if handled aggressively, are likely to remain on the each year's report even if the tenants have agreed to pay the bills and no additional arrearages are being accumulated. Identification of landlord status will therefore be useful.

•Other data points: For the reasons set forth above with respect to formal and informal complaints, PECO believes it may be useful to report the number of medical certificates granted on the account over the last two years. It may also be helpful to know whether the customer is on PECO's CAP program. Finally, it may be useful to know when the customer made their last payment.

Arrearage Reporting Proposal Point 5: The Commission may request more detailed follow-up information on specific accounts.

PECO Comments on Point 5: In PECO's experience, residential accounts that reach this level of

delinquency typically have a convoluted multi-year history involving multiple customer formal and

informal complaints, high bill inquiries, medical certificates, utility reports, transfer balances, and other

complex procedural background. Further, it can take a trained regulatory assessor or other analyst

several business days to research and summarize the data on an account at this level of complexity.

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PECO recognizes that the Commission will need to understand this complex background for some

accounts, but requests that in making such requests the Commission be cognizant of the very heavy

requirement such requests place on PECO's regulatory analysts.

Arrearage Reporting Proposal Point 7: 0 Reports shall be formatted per a specific spreadsheet format provided by the Commission. The Commission will provide this format by the end of calendar year 2015.

PECO Comments on Point 7:

As with the medical certificate reporting, PECO agrees that the Commission should provide a common

spreadsheet format that incorporates its resolution of the issues raised above (and any similar issues

raised in the comments of other stakeholders). However, for the arrearage review, the data points are

likely to be much more complex than for the medical certificate reporting. It is therefore even more

imperative that the Commission provide its spreadsheet as soon as possible -and certainly well before

the end of the year - to allow PECO to determine whether its IT systems can support the requested data

reporting and, if not, the cost and timing of changing its system to support the data reporting.

Respectfully submitted,

Ward Smith

Assistant General Counsel

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