0000004276.00000 Advice 4276-E: Southern California Edison ... · ADVICE 4276-E (U 338-E) - 2 - August 17, 2020 (OP 41). BACKGROUND On July 20, 2018, the Commission issued Rulemaking

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 Fax (626) 302-6396

1. Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations

August 17, 2020

ADVICE 4276-E (U 338-E)

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION

SUBJECT: Southern California Edison Company’s Plan to Implement Requirements in Support of the Medical Baseline Program, Pursuant to Decision 20-06-003, Ordering Paragraphs 36 through41

PURPOSE

Southern California Edison Company (SCE) hereby submits this Tier 3 Advice Letter (AL) pursuant to Ordering Paragraphs (OP) 36 through 41 in California Public Utilities Commission (Commission or CPUC) Decision (D.)20-06-003. The purpose of this AL is to demonstrate compliance with those specific OPs that require SCE to provide:

• A procedure to allow qualified medical professionals to e-sign applications for the Medical Baseline program (OP 36);

• Annual training to county health workers that do in home visits before the second quarter of each year (OP 37);

• Outreach and educational materials in multiple languages for county health workers to take into the field (OP 38);

• Plans demonstrating SCE’s coordination with the medical community and county public health offices to increase marketing and outreach to persons eligible for the Medical Baseline allowance as well as outlining SCE’s plans to implement Senate Bill (SB) 1338 requirements to allow qualified medical professionals to complete applications for the Medical Baseline program including the use of e-signatures. (OP 39);

• Plans outlining the implementation of SB 1338 requirements including enrollment goals and metrics that identify the number of customers reached and ultimately enrolled in the Medical Baseline program. (OP 40); and

• Plans for funding outreach and grants to Community Based Organizations (CBOs) who promote public outreach related to the Medical Baseline program.

ADVICE 4276-E (U 338-E) - 2 - August 17, 2020

(OP 41).

BACKGROUND

On July 20, 2018, the Commission issued Rulemaking (R.)18-07-005 to implement the requirements of SB 598 in order to address “disconnection rates across California’s electric and gas investor-owned utilities by adopting policies and rules that reduce disconnections and improve reconnection processes and outcomes for disconnected customers.”1 On September 18, 2018, SB 1338 was signed by Governor Brown prohibiting the disconnection of service where a physician assistant certifies that the gas or electric service is medically necessary to sustain the life of the customer or member of the customer’s family, or to prevent deterioration of that person’s medical condition. SB 1388 also required the Commission to develop rules to demonstrate that the four largest energy utilities demonstrate that they are working with the medical community to increase marketing and outreach to persons eligible for the Medical Baseline allowance.

On December 19, 2018, the Commission issued D.18-19-013 as an interim decision in this proceeding which included provisions regarding Medical Baseline, customers 65 years and older, and customer protections during extreme weather conditions. On June 16, 2020, the Commission issued D.20-06-003 (the Decision), Phase 1 adopting rules designed to reduce the number of residential customer disconnections. The Decision adopted, with modifications, the interim provisions from D.18-19-013.

In the Decision, the Commission ordered the Investor Owned Utilities (IOUs) to submit a Tier 3 AL that:

• Demonstrates coordination with the medical community and county public health offices to increase marketing and outreach to persons eligible for Medical Baseline;

• Provides an outline for plans to implement the requirements of SB 1388 including plans to allow qualified medical professionals to e-sign Medical Baseline program applications;

• Provides Medical Baseline program enrollment goals and metrics; and • Plans for funding outreach programs and grants to CBOs who promote public

outreach related to the Medical Baseline program.

1 R.18-07-005, Order Instituting Rulemaking (OIR), p.1.


DISCUSSION

I. Medical Baseline Program and Plans to Allow Qualified Medical Professionals to Electronically Sign Applications

A. Description of SCE’s Medical Baseline Program

SCE’s Medical Baseline program, as approved by the Commission, is described in the Preliminary Statement tariff within its Tariff Book,2 which provides, upon application by the customer, an increased daily baseline allowance for eligible customers using one or more specified life-support devices as prescribed by a medical provider. The certification and verification requirements are also described in SCE’s Preliminary Statement including certification by their medical provider that the customer household is temperature sensitive and requires air conditioning or has a life-threatening illness or other condition that requires heating and/or cooling. A list of the qualifying medical devices for the Medical Baseline program is identified in SCE’s Preliminary Statement and can also be found at SCE’s Medical Baseline website.3 Specifically, the Medical Baseline program provides an additional 16.5 kilowatt-hours (kWh) of electricity per day at the lowest baseline rate, which helps offset the cost of operating the medical equipment. Customers may contact SCE directly if the standard allowance does not meet their medical needs.4 As of January 1, 2019, consistent with SB 598 and SB 1338, SCE accepts Medical Doctors (MD), Doctor of Osteopathys (DO), Physician Assistants (PA), or Nurse Practitioners (NP) to certify that a customer qualifies for the Medical Baseline program.5

Because the use of medical devices has a direct impact on a Medical Baseline customers’ energy use, SCE takes extra steps to inform Medical Baseline customers of de-energization events. These steps include automatically contacting Medical Baseline customers with a pre-recorded telephone message when the California Independent System Operator (CAISO) declares a rare Stage 3 Emergency and enacts rolling outages. In the event a Public Safety Power Shutoff (PSPS) is called, SCE will attempt to reach Medical Baseline customers through their alternate preferred method of contact. If a physician has indicated that a customer has medical equipment for life sustaining purposes and SCE is unable to reach the customer directly, SCE will send a technician to the customer residence to make in-person contact regarding the PSPS event.

In response to the impact of the COVID-19 pandemic on customers, SCE has temporarily changed the requirements for customers to enroll and recertify for the Medical Baseline program so that vulnerable customers can continue to benefit from the

2 SCE Preliminary Statement Paragraph H: https://library.sce.com/content/dam/sce-doclib/public/regulatory/tariff/electric/preliminary-statements/ELECTRIC_PRELIM_H.pdf

3 https://www.sce.com/residential/assistance/medical-baseline 4 Please call 1-800-655-4555 if the standard allowance does not meet your medical needs. 5 See Advice 3923-E-A, effective January 1, 2019.


Medical Baseline program. Customers who use electronically powered medical equipment can temporarily enroll in the Medical Baseline program without a qualified medical professional’s signature until April 16, 2021. Customers already enrolled in the Medical Baseline program who were due to renew between March 4, 2020 and April 16, 2021, will continue to be enrolled in the program. These renewals will be postponed for one year from the original renewal date in 2020.

B. Electronic Signature for Medical Professionals to Certify Customer Eligibility

In OPs 36 and 39, the Commission directed SCE to essentially create an online pathway for qualified medical professionals to electronically certify customer eligibility in the program. SCE has already begun to implement this direction. In fact, in response to the COVID-19 pandemic, SCE has already implemented an online application with electronic signature capability for the customer via DocuSign on its Medical Baseline program website. The online portal currently allows customers to electronically fill out and submit an application to enroll in the Medical Baseline program. The standard application and informational brochures are currently available in six additional languages.6 SCE is currently working to enhance the online application by providing translations in alternate languages and accessibility for a screen reader.

SCE’s current process does not yet allow for qualified medical professionals to electronically certify customer eligibility. However, at this time SCE does not require any certification from qualified medical professionals until the end of the Emergency Consumer Protections. SCE is determining the optimal approach to accomplish an electronic certification system for qualified medical professionals prior to the end of Emergency Consumer Protections in April 2021. SCE recognizes that any solution must consider customer privacy and cybersecurity requirements. Additionally, overall cost to all SCE customers, customer accessibility, ease of implementation, and outreach must also be considered to find the optimal approach for SCE’s customers. SCE will consider all these factors to implement necessary modifications to this e-signature process in a timely fashion.

II. Coordination with the Medical Community and County Public Health Offices for Annual Training and to Increase Marketing and Outreach

In OP 37, 38 and 39, SCE is required to outline its plans demonstrating coordination with the medical community and county public health offices to increase marketing and outreach to persons eligible for the Medical Baseline program as well as providing annual training and outreach and educational materials for county health workers to take into the field.

SCE’s coordination with the medical community and county public health offices will continue to leverage its current and successful working experience with the CBOs within

6 Additional available languages are Spanish, Korean, Chinese, Vietnamese, Cambodian, and Tagalog.


its service territory including developing talking points and sharing best practices to drive program participation. Additionally, SCE will continue building upon its established relationships with county health workers through its PSPS-related activities. Specifically, SCE will develop a comprehensive list of county public health offices in order to coordinate with those offices and offer training as required in OP 37. In addition, SCE will create specific points of contact for the county health workers, so they are able to request additional assistance or receive clarification on any of the materials presented and allow SCE to respond to any additional questions.

SCE also plans to develop a training curriculum and coordinate with County Health and Human services as well as the Public Health Department in the first quarter of 2021, and each first quarter of subsequent years, to conduct an annual series of training sessions with their respective organizations. These trainings will aim to educate their staff on available programs at SCE that can aid members of their communities, including Medical Baseline, low income programs, rebates and incentives. Additionally, SCE will ensure that outreach and educational materials are made accessible to these organizations in the prevalent languages throughout its service territory, so that county health workers can take these materials to the field. Medical Baseline applications and brochures are currently available in English, Spanish, Korean, Chinese, Vietnamese, Cambodian, and Tagalog.

III. Engagement with CBOs and Funding Outreach Programs and Grants to CBOs Promoting Medical Baseline Outreach

OP 41 requires that SCE explain its plans for engagement with its CBOs. The Medical Baseline program outreach is integrated into SCE’s overall strategy to increase awareness and education for customers about its rates and assistance programs.

SCE has relationships with more than 1,600 CBOs and faith-based organizations (FBOs) within its service territory of which many reach underserved customer segments. SCE actively communicates with these CBOs and are engaged quarterly and on an as needed basis. To create productive alliances with key CBOs, particularly those that reach critical customer segments like Seniors, Low Income, Disabled, and Multi-Cultural, SCE launched a pay-for-performance model in 2019 and contracted 30 CBOs for ongoing incentivized partnerships. These CBOs were selected through a Request for Proposal (RFP). The RFP was designed to select a total of 30 CBOs that have a strong reach within diverse communities and demonstrate a strong ability to partner with SCE to help educate customers in valuable programs and services.

Together, the CBOs, FBOs, and SCE share information about programs such as rate options that can help customer reduce their bills, including programs such as CARE/FERA and the Medical Baseline Allowance program. CBOs and FBOs, also regularly exchange and share communications on programs and service through social media, e-newsletters, and direct stake holder engagement efforts like digital webinars.


Finally, SCE has established partnerships with the eight designated independent living centers (ILC) operating under the California Foundation for Independent Living Centers (CFILC) umbrella within the SCE service territory, to help prepare Access and Functional Needs (AFN) communities for PSPS events. The ILCs are dedicated to increasing independence, access, and equal opportunity for people with disabilities in Inyo, Kern, Los Angeles, Mono, Orange, Riverside, San Bernardino, Santa Barbara, and Ventura Counties. In 2019, these ILCs received funding to conduct and promote emergency preparedness, planning and training activities. Outreach also includes awareness and assistance in applying for SCE’s Medical Baseline program. These activities are closely monitored and adjusted through meetings with the individual ILCs and quarterly meetings with all ILCs. The ILCs are in strong consideration for funding in 2020; the final deliverables and completed impact reports will be used to determine the ongoing partnerships.

IV. Enrollment Goals and Other Metrics

OP 40 of the Decision requires that SCE provide enrollment goals, in order to increase enrollment in the Medical Baseline program above 2018 levels.7 As shown in the table below, SCE’s household enrollment in the Medical Baseline program at the end 2018 was 99,132 and 95,915 in 2019. As shown in Table 1 below, SCE experienced a 5.4 percent increase to 101,113 customers enrolled in 2020 (year to date through July) when compared to the end of 2019. When comparing 2020 to end of 2018, SCE experienced a 2.0 percent increase over that time period.

Table 1: Medical Baseline Program Historical Household Enrollments (2018-2020 Year-To-Date)

Program Year Household

Enrollments (End of Year)

Percent Change from Previous

Year

2018 99,132 -

2019 95,915 (3.2%)

2020 (through July) 101,113 5.4%

As stated in the previous section explaining the Medical Baseline program, SCE

responded to the COVID-19 pandemic by temporarily suspending the medical professional certification process for customer enrollment. Table 2 below shows a significant increase in 2020, particularly in the months following the implementation of the Emergency Consumer Protections.

7 D.20-06-003, p.78.


Table 2: Medical Baseline Program Enrollment in 2020 (Year-to-Date)

Med Baseline Program 2020 Jan Feb Mar Apr May Jun July

Total Med Baseline Customers 95,936 96,219 96,739 97,321 98,875 100,079 101,169

Percent Change from Previous Month 0.3% 0.5% 0.6% 1.6% 1.2% 1.1%

In proposing future enrollment goals, SCE recognizes the intent of the Decision to

increase overall enrollment in the program relative to 2018. The state is experiencing unprecedented impacts from the COVID-19 pandemic, which is driving growth in the Medical Baseline program. The duration of the impact from the pandemic upon our customers’ health is yet to be determined. SCE is also optimistic the additional coordination with county health workers will further drive enrollment within the program. However the Medical Baseline program is also limited to customers using medical devices in their homes and SCE must consider the customer’s right to privacy and respect their individual choices with regard to program enrollement. These considerations create difficulty in estimating a reachable target rate for increased enrollment. Recognizing all of these factors, SCE reasonably proposes an annual three percent target increase each year for 2021-2023.

Table 3: Proposed Enrollment Goals

Program Year

Household Enrollments (End of Year)

Percent Change from Previous Year

2021 104,146 3%

2022 107,270 3%

2023 110,270 3%

To assist in determining an enrollment goal that considers the appropriate variables

and influencing factors, SCE recommends a comprehenisve study be completed to determine the potential eligible population by each IOU. This study approach is currently done for other low income customer assistance programs (Low Income Needs Assessment). The results of this study would allow the IOUs to properly adjust their goals accordingly. The study would also help identify certain areas of the service territory that are underserved. Additionally, SCE will track its outreach activities and the number of customers reached through those strategies. This combination of data would help to determine which solutions may be more effective and better guide future efforts


for customer outreach. Once better information is gathered and the impact of the pandemic on Medical Baseline enrollment is analyzed, SCE recommends revisiting these annual goals and adjusting as appropriate.

V. Eligible Costs Tracking

The Decision allows SCE to establish a memorandum account to track the costs associated with implementing the requirements of the Decision.8 At this time, the potential costs associated with creating a portal for qualified medical professionals to electronically certify customer eligibility and the incremental costs associated with the other items addressed in this advice letter are still to be determined. Additionally, SCE will be submitting a separate advice letter to establish the memorandum account to track implementation costs associated with the requirements of the Decision. As such, SCE’s intends to track all of these costs within the memorandum account once the account has been approved by the Commission.

VI. Recommendations from Energy Division

On August 10, 2020, the IOUs met with Energy Division (ED) regarding this advice letter. ED provided the IOUs with preliminary feedback and recommendations regarding the Medical Baseline program. SCE appreciates the innovative recommendations proposed by ED. Once SCE has assessed the ED recommendations, SCE will seek further engagement with ED to discuss those recommendations including incorporating feasible recommendations into outreach for the Medical Baseline program.

TIER DESIGNATION

Pursuant to OP 39 of D.20-06-003, SCE submits this advice letter with a Tier 3 designation.

EFFECTIVE DATE

This advice letter will become effective upon Commission approval. NOTICE

Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to:

8 D.20-06-003, OP 95.


CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: [email protected]

Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above).

In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of:

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770

Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail: [email protected] Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: [email protected]

There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above.

In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and R.18-07-005 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to [email protected] or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at [email protected].

Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters.


For questions, please contact Eric Lee at (626) 302-0674 or by electronic mail at [email protected].

Southern California Edison Company

/s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D.

GAS:el:jm

ADVICE LETTER S U M M A R YENERGY UTILITY

Company name/CPUC Utility No.:

Utility type:Phone #:

EXPLANATION OF UTILITY TYPE

ELC GAS

PLC HEAT

MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Advice Letter (AL) #:

WATERE-mail: E-mail Disposition Notice to:

Contact Person:

ELC = ElectricPLC = Pipeline

GAS = GasHEAT = Heat WATER = Water

(Date Submitted / Received Stamp by CPUC)

Subject of AL:

Tier Designation:

Keywords (choose from CPUC listing):AL Type: Monthly Quarterly Annual One-Time Other:If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:

Does AL replace a withdrawn or rejected AL? If so, identify the prior AL:

Summarize differences between the AL and the prior withdrawn or rejected AL:

Confidential treatment requested? Yes NoIf yes, specification of confidential information:Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information:

Resolution required? Yes No

Requested effective date: No. of tariff sheets:

Estimated system annual revenue effect (%):

Estimated system average rate effect (%):

When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting).

Tariff schedules affected:

Service affected and changes proposed1:

Pending advice letters that revise the same tariff sheets:

1Discuss in AL if more space is needed.

CPUC, Energy DivisionAttention: Tariff Unit505 Van Ness AvenueSan Francisco, CA 94102 Email: [email protected]

Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx:Facsimile (xxx) xxx-xxxx:Email:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx:Email:

Zip:

Zip:

mailto:EDTariffUnit%40cpuc.ca.gov?subject=

ENERGY Advice Letter Keywords

Affiliate Direct Access Preliminary StatementAgreements Disconnect Service ProcurementAgriculture ECAC / Energy Cost Adjustment Qualifying FacilityAvoided Cost EOR / Enhanced Oil Recovery RebatesBalancing Account Energy Charge RefundsBaseline Energy Efficiency ReliabilityBilingual Establish Service Re-MAT/Bio-MATBillings Expand Service Area Revenue AllocationBioenergy Forms Rule 21Brokerage Fees Franchise Fee / User Tax RulesCARE G.O. 131-D Section 851CPUC Reimbursement Fee GRC / General Rate Case Self GenerationCapacity Hazardous Waste Service Area MapCogeneration Increase Rates Service OutageCompliance Interruptible Service SolarConditions of Service Interutility Transportation Standby ServiceConnection LIEE / Low-Income Energy Efficiency StorageConservation LIRA / Low-Income Ratepayer Assistance Street LightsConsolidate Tariffs Late Payment Charge SurchargesContracts Line Extensions TariffsCore Memorandum Account TaxesCredit Metered Energy Efficiency Text ChangesCurtailable Service Metering TransformerCustomer Charge Mobile Home Parks Transition CostCustomer Owned Generation Name Change Transmission LinesDecrease Rates Non-Core Transportation ElectrificationDemand Charge Non-firm Service Contracts Transportation RatesDemand Side Fund Nuclear UndergroundingDemand Side Management Oil Pipelines Voltage DiscountDemand Side Response PBR / Performance Based Ratemaking Wind PowerDeposits Portfolio Withdrawal of ServiceDepreciation Power Lines

Documents

0000004276.00000 Advice 4276-E: Southern California Edison ... · ADVICE 4276-E (U 338-E) - 2 - August 17, 2020 (OP 41). BACKGROUND On July 20, 2018, the Commission issued Rulemaking