VII. Miscellaneous Implementation Issues

ORA expresses concern that the schedule in the OIR provides for only a single workshop to revise the language of GO 153 after the Commission issues its decision adopting enrollment and verification rules. ORA would have us conduct another workshop prior to issuance of this decision. After reviewing the record of this proceeding, we determined that we have an adequate record to move forward to adopt the framework for a new certification/verification system for the ULTS program. However, there are some issues where the record could be augmented, and we will do that in a workshop setting. We will defer to TD, as to the number and length of workshops needed.

Cox indicates that carriers should be permitted to recover the administrative costs of transitioning to a single certification entity. We concur that carriers should be permitted to recover administrative costs during the transition period, but we will defer to the workshop to develop a more detailed plan.

ORA expresses the need to have a transition period that allows service providers and customers to adjust to the new procedures and minimize program disruption. This issue should also be addressed in workshops.