12. CARE Outreach and Recertification

The CARE program requires proof of income eligibility, as well as recertification on a scheduled basis to ensure customers remain eligible. These requirements are essential to ensure that customers receiving the very significant energy bill subsidies CARE provides be qualified based on income.

By the same token, many customers are dropped at recertification. We make slight modifications to the relevant SMJUs' programs to ensure that those dropped are truly ineligible, rather than simply customers who are not given a reasonable opportunity to recertify eligibility.

Southwest Gas: Over 25% of Southwest Gas' CARE customers scheduled for recertification during 2007 were removed from the CARE program due to their failure to recertify program eligibility. Southwest Gas sent these customers multiple mailings notifying them of their upcoming enrollment expiration, along with an automated reminder call as required by D.05-07-014.²⁴ Southwest is implementing a recertification initiative to reach those who may still qualify for CARE but have not responded to the standard recertification attempts. Southwest sent an "attractive" self-mailer, with an application attached, to identified customers during summer 2008. It will track the success of the initiative. We require Southwest to report the results of its tracking with its May 1, 2009 annual report.²⁵ Southwest shall also report the number of complaints (however received) stemming from its recertification efforts, and discuss what it is doing to ensure it is only losing customers that are not CARE-eligible.

Southwest Gas notes that it has had a lot of success enrolling customers via the Internet. It is unclear whether it uses an online process for recertification; if it does not, it should do so in a manner that secures the privacy of customer financial data and report the results of doing so with the May 1, 2009 annual report as well.²⁶

Southwest asks the Commission to require recertification every other year, rather than annually, for submetered and "expanded CARE programs." "Expanded CARE programs" are nonprofit group living facilities, migrant farm worker housing centers, privately-owned employee housing, and agricultural employee housing.²⁷ Southwest justifies the change for submetered customers on the grounds that it will make the program consistent with how it treats all other CARE customers. There certainly is no reason to differentiate among submetered customers - some of the poorest customers in the state - and those with their own meters. We grant Southwest's request.

Southwest justifies the request regarding expanded CARE programs by noting that the housing does not change from year to year, so any residents in the housing tend to be eligible for CARE by virtue of living in the housing. We grant this request as a rational means of balancing the need to screen out ineligible customers against the risk of losing eligible customers through unnecessary recertification requirements.

PacifiCorp: PacifiCorp recertifies customer eligibility every two years. It sends "a letter with a recertification form and postage paid return envelope to each customer that has participated in the program for the last two years,"²⁸ and a second letter 45 days later. PacifiCorp has very high CARE penetration levels (78% of eligible customers as of May 2008) - and indeed received plaudits from DRA for its success in achieving high levels. The company does not indicate that it has experienced CARE drop-offs during recertification.

Bear Valley: Bear Valley's CARE penetration levels are fairly low (approximately 55% of those eligible as of December 31, 2007). It has experienced a decline in CARE enrollment over the past few years. The main driver of such decline, according to Bear Valley, is recertification.²⁹ Bear Valley plans to be more proactive in the future by following up with customers who do not reply to recertification notices, and working more closely with Southwest Gas to identify customers who are enrolled in CARE in one but not both utility programs.

We do not know if Bear Valley's recertification efforts are causing large numbers of customers to drop out of the program, and if so, how many of those are eligible CARE customers who simply fail to return the recertification forms.

Discussion: Because Bear Valley has unduly low CARE penetration levels and attributes some of this problem to CARE recertification, we grant Bear Valley additional funding, some of which should be devoted to following up with customers who do not recertify eligibility for CARE. We expect Bear Valley's annual reports to demonstrate that enhancements to its recertification process are working, and if they are not, to identify additional efforts the company will take. Obviously, Bear Valley should not reenroll customers who are not eligible, but since its penetration level is only 55% of eligible CARE customers, clearly its efforts fall short of ideal. Bear Valley should also report on CARE drop-offs on recertification in its May 1, 2009 annual report, and give the number of complaints (however received) stemming from its recertification efforts.

²⁴ Southwest Gas Application, p. 13.

²⁵ Southwest provides its applications and recertification forms in both English and Spanish.

²⁶ We extend these privacy and reporting requirements to the other SMJUs who use the Internet for recertification.

²⁷ Southwest Application, p. 10.

²⁸ PacifiCorp Application, p. 7.

²⁹ Bear Valley Application, p. 7.