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Assessment of compliance with regulatory framework for customer
service by:
Dhofar Power Company SAOC
Majan Electricity Company SAOC,
Mazoon Electricity Company SAOC,
Muscat Electricity Distribution Company SAOC and
Rural Areas Electricity Company SAOC
Project reference AER 01/2016
OVERVIEW COMPLETION REPORT
Publication version
Submitted by energypeople limited
October 2016
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Contents
1 Executive summary ........................................................................................................ 8
1.1 Overview ......................................................................................................................... 8
1.2 Summary of Sector Wide Recommendations ....................................................... 11
2 Introduction ................................................................................................................... 13
2.1 About this report .......................................................................................................... 13
2.2 Background.................................................................................................................. 13
2.3 Scope ............................................................................................................................ 14
2.4 Acknowledgement .................................................................................................... 15
3 Approach ....................................................................................................................... 16
3.1 Phase 1 - Overview visits ............................................................................................ 16
3.2 Phase 2 – Detailed reviews of licence compliance ............................................. 16
3.3 Phase 3 - Review, report and provide feedback ................................................. 16
4 Methodology ................................................................................................................. 17
4.1 Assessment criteria – Themes in the ToR ................................................................. 17
4.2 Assessment criteria – Detailed Licence and Code Compliance ...................... 17
5 Findings ........................................................................................................................... 18
5.1 Phase 1 Overview Assessment.................................................................................. 18
5.1.1 Understanding of Regulatory Framework ....................................................................... 18 5.1.2 Well defined business owners for each Regulatory Obligation .................................. 18 5.1.3 Sufficient Risk Management on Regulatory Obligations ............................................. 19 5.1.4 Adequate IT systems for internal reporting ..................................................................... 20 5.1.5 No conflicting instructions ................................................................................................. 21 5.1.6 Adequacy of SLAs and Contracts ................................................................................... 21 5.1.7 Phase 1 Overview Assessment All Company Comparison .......................................... 23
5.2 Detailed licence and code compliance ............................................................... 23
5.2.1 Meter reading (Verification that KPI data matches contractor records) ................ 23 5.2.2 Meter reading (Verification of DLP problems) ............................................................... 24 5.2.3 Late Payment Code of Practice (Ability to pay guidelines) ....................................... 26 5.2.4 Late Payment Code of Practice (Disconnection Notices) ......................................... 28 5.2.5 Complaint Handling Procedure (Quality of response) ................................................ 29 5.2.6 New connections (Time taken to connect) ................................................................... 30 5.2.7 Special Needs Customers (Delivery of COP) ................................................................. 33 5.2.8 Outage Management (Customer communications) .................................................. 34 5.2.9 Quality of Front Line Advice .............................................................................................. 35 5.2.10 Phase 2 Specific Assessment All Company Comparison............................................. 36
6 Overview of licence and code compliance .......................................................... 38
6.1 Company O ................................................................................................................. 38
6.2 Company I ................................................................................................................... 39
6.3 Company S .................................................................................................................. 40
6.4 Company D.................................................................................................................. 41
6.5 Company C ................................................................................................................. 42
7 Appendix 1: Phase 1 Overview Questions Template ............................................. 43
8 Appendix 2: Phase 1 Overview Assessment Criteria .............................................. 64
9 Appendix 3: Phase 2 Code Specific Assessment Criteria ..................................... 70
10 Appendix 4: Comparison of Existing Contract Features ....................................... 80
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11 Appendix 5: Proposed Template for AER KPI returns ............................................. 82
List of figures
Figure 1 Approach to the compliance assessment ................................................................. 16
Figure 2: Generic new connections process ............................................................................. 32
Figure 3: Company O Overview Assessment............................................................................. 38
Figure 4: Company O Company Specific Code Assessment ................................................ 38
Figure 5: Company I Overview Assessment ............................................................................... 39
Figure 6: Company I Specific Code Assessment ...................................................................... 39
Figure 7: Company S Overview Assessment .............................................................................. 40
Figure 8: Company S Electricity Company Specific Code Assessment ............................... 40
Figure 9: Company D Overall Assessment ................................................................................. 41
Figure 10: Company D Specific Code Assessment .................................................................. 41
Figure 11 Company C Overall Assessment ................................................................................ 42
Figure 12: Company C Specific Code Assessment .................................................................. 42
List of tables
Table 1: Summary of Sector wide Recommendations ............................................................ 12
Table 2: Phase 1 Overview Compliance - All Company Comparison ................................. 23
Table 3: Comparison of Payment Arrangements ..................................................................... 27
Table 4: Customers Disconnected for Non-Payment .............................................................. 28
Table 5: Customer Complaints by Category First Quarter 2016 ............................................. 30
Table 6: Service Centre Comparison .......................................................................................... 36
Table 7: Phase 2 Specific Compliance Assessment - All Company Comparison .............. 37
Table 8: Phase 2 General Assessment Criteria .......................................................................... 70
Table 9: Meter Reading KPI Assessment Criteria ....................................................................... 71
Table 10: Meter Reading DLP Assessment Criteria ................................................................... 72
Table 11: Late Payment Code of Practice Assessment Criteria ............................................ 73
Table 12: Complaint Handling Code of Practice - Assessment Criteria ............................... 75
Table 13: Network Connections Assessment Criteria ............................................................... 76
Table 14: Special Needs Code of Practice - Assessment Criteria ......................................... 77
Table 15: Outage Management (Customer communications) - Assessment Criteria ...... 78
Table 16: Quality of Front Line Advice - Assessment Criteria .................................................. 79
Table 17: Comparison of existing MRBC contract arrangements ......................................... 81
Table 18: Sample proposed workbook for meter reading KPI returns .................................. 82
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Document control
Description and status
Title Assessment of Distribution Companies‟ compliance with regulatory
framework for customer service
Reference AER 01/2016
Issue number 1.1
Date 11 October 2016
Authorisation
Name Position Signed Date
Bill Slegg Project Leader 11 October 2016
History
Issue Date Author Reviewers Description
0.1 1 September
2016
Team Bill Slegg Draft (internal only)
0.2 15 September
2016
Team Simon Faiers Draft Completion Report for
review by AER
1.0 6 October
2016
Team Bill Slegg Final Incorporating AER
comments
1.1 11 October
2016
Glen Chapman Simon Faiers Final incorporating AER Director
of Customer Affairs comments
Copyright, warranties and disclosure
This report is submitted by energypeople limited, Lodge Lane Business Centre, Lodge Lane, Langham,
Colchester, EssexCO4 5NE, United Kingdom. It has been prepared on the basis of information made
available by the customer, together with material, which is in the public domain. Though we have taken all
reasonable care to expose our analysis, assumptions and projections, we offer no warranty or guarantee as
to their certainty and accept no responsibility or liability for the consequences of this document being used
for a purpose other than the purpose for which it was commissioned. This report is the copyright of
energypeople limited. It has been commissioned by and prepared for the Authority for Electricity
Regulation and is intended to be used by them freely, subject only to any legal limitations preventing the
disclosure of information regarded as confidential.
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Glossary of terms
In what follows we list the abbreviations and short forms used in this report and the
meanings attached to them. Some are specific to this report and should not be
taken as an authoritative glossary of terms as they are used elsewhere in the sector.
AER The Authority for Electricity Regulation, Oman. Also referred to as „the
Authority‟. Established by Article (19) of the Sector Law
AMR Automated meter reading
Blueprint The organisational and process redesign Blueprint for the customer service
function of electricity supply and distribution companies in Oman.
Commissioned by EHC, developed by ESBI, in the implementation phase at
the time of this report
CHP Complaint Handling Procedure (licence condition 24 for MIS licensees)
CI Customer interruptions (to their electricity supply)
CoP Code of Practice
Cost
Reflective
Tariff
Amounts charged by OETC and licensed Distribution System Operators for
connection and use of their systems, and amounts charged by Licensed
Suppliers in consideration for supply where no Permitted Tariff exists
CML Customer minutes lost
CRM Customer Relationship Management (usually referring to the IT support CRM
system used in four companies)
DCRP Distribution Code Review Panel
DLP Door locked permanently (meaning no access for meter readers)
DPC Dhofar Power Company SAOC, distribution and supply licence holder,
Nama Group
EHC Electricity Holding Company, Nama Group. Controlling shareholder of the
distribution companies
HHD Hand held device (for meter reading)
IVR Interactive Voice Response, an automated telephony system (used in
companies‟ contact centres) that interacts with callers, gathers information
and routes calls to the appropriate team/team member.
KPI Key performance indicator, specifically those on which companies are
required to report to AER quarterly
Licence An authorisation granted by the Authority to undertake one or more of the
Regulated Activities stipulated in Article (3) of the Sector Law
LPCOP Late Payment Code of Practice (licence condition 41 for MIS licensees)
MEDC Muscat Electricity Distribution Company SAOC, distribution and supply
licence holder, Nama Group
MIS Main interconnected system supplying the northern part of the Sultanate,
including the MEDC, MJEC and MZEC networks (not management
information system as used when discussion information technology
matters)
MJEC Majan Electricity Company SAOC, distribution and supply licence holder,
Nama Group
MMRS Manual Meter Reading System (in implementation phase at the time of this
report, covering HHD, route planning and navigation, in field billing etc).
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Also shortened to MMR
MRBC Meter reading, billing and collection. (This is the full meter reading, billing,
bill printing and delivery and cash collection process that has historically
been outsourced to a service provider ; however with the exception of DPC
billing is now typically carried out in-house)
MZEC Mazoon Electricity Company SAOC, distribution and supply licence holder,
Nama Group
Nama Group The new name of the Electricity Holding Company (EHC), Controlling
shareholder of the distribution companies
OETC The Oman Electricity Transmission Company SAOC
OIFC Oman Investment & Finance Co. SAOG (service provider to MEDC for meter
reading, bill printing and distribution and cash collection)
Omanisation Policy for the employment of Omani nationals as issued by the Government
of Oman
ONEIC Oman National Engineering and Investment Co. SOAG (service provider
under contract in various forms to DPC, MJEC, MZEC and RAEC for meter
reading, bill printing and distribution and cash collection)
OPWP Oman Power and Water Procurement Company SAOC
PPM Prepayment meter (prepayment metering)
RAEC The Rural Areas Electricity Company SAOC, distribution and supply licence
holder, Nama Group
Sabiq The MEDC prepayment metering set up (and programme)
SLA Service level agreement (in this context an internal SLA between distribution
and supply, integral to Blueprint implementation)
SMS Short Message Service. Also referred to as text messaging
SN Special Needs, or SNC meaning Special Needs Customers. Meaning those
customers who qualify for treatment under licence condition 41 (for MIS
licensees).
VoC Voice of the customer (independent survey of customer opinion
commissioned by EHC/Mama)
Worst served
customer
Term used in regulation to identify those customers least well served e.g. in
terms of a reliable electricity supply - CMIs, CMLs, or meter being unread
etc (as distinct from KPIs based on total or average achievement)
Note: references to licence conditions apply to MIS licensees. The same licence conditions
apply to DPC and RAECO, but with different numbers and with the exception that RAECO‟s
CHP reflects a company undertaking to the Authority rather than a specific licence
requirement.
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1 Executive summary
1.1 Overview
This report presents a sector wide overview of the assessment of Licensees‟
compliance with the Regulatory Framework for Customer Service in Oman. It is
accompanied by five Company Specific Reports which provide a further level of
detail, including focused recommendations.
The assessment was carried out by a team consisting of staff from AER and from
energypeople limited. It comprised two rounds of visits to licensees. The first round
looked at each licensee‟s understanding of its regulatory obligations, its readiness to
deliver them, management of risk and issues that might hinder delivery such as
contracts and inadequate information systems. The second round looked more
deeply into specific areas of compliance with Licence Conditions and Codes of
Practice requirements. In addition members of the AER team conducted a phone
survey of customers to obtain first hand feedback on the service being provided.
As may have been expected the differences between companies were quite
noticeable. This reflects both differences in historic organisational structures,
management approaches and the customer base and also differences in progress
with and commitment to implementation of the Blueprint for customer service,
including resourcing; preparation for business separation; the introduction of new
information systems; and increasing commercial pressure.
All companies, to different degrees, outsource their meter reading, billing, bill
delivery and account collection activities, though all but Company O have now
moved billing in house. This means that contractors manage the main interface
with customers and the delivery of a large number of regulatory obligations. In
some licensees there has been little recognition that while the activities are
outsourced, the regulatory obligation remains with the licence holder and the
contractor must be actively and effectively managed in order to deliver them. All
licensees must do more to ensure that contractors properly represent them, e.g. by
wearing uniforms, by carrying proper identification and by applying appropriate
standards of customer service in their account collection offices. Furthermore, at a
fundamental level it must be made clear to customers that it is the licensee who is
their electricity supplier, not the contractor. There is anecdotal evidence across the
sector that this may still not be well understood and communications designed to
reinforce the supplier‟s role are limited.
Contract management is a key issue and all companies could do much better. On
a commercial front they all tend to manage contracts by percentage performance
against KPI targets and by an absence of formal complaints. Regulatory obligations
and “worst served customers” do not appear to be key items for discussion. Indeed,
there seems to be a preference not to look too closely, to assume that if problems
are not transparent they do not exist and then only to react when problems have
escalated to a significant extent. A more proactive approach is certainly now
required.
The existing MRBC contracts are at different stages. Company S has a relatively new
contract with enhanced performance measurement, while Company O still has an
unsuitable legacy contract which is not compatible with its regulatory requirements
and in some aspects may potentially be working against them. This contract expires
early in 2017.
On the other hand Company D is placing three new zonal and unbundled meter
reading, bill printing and delivery contracts to apply from January 2017 and, if
appropriately managed, combined with new systems and hand held meter reading
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devices will be a big step in the right direction. Company C is progressing similarly,
with Company I a little further behind.
There is a need to end the hostility and lack of respect that, combined with a laissez
faire attitude to contract management, seem to have characterised contractual
relationships in the past and to have allowed commercial objectives to over-ride
regulatory standards and good customer service.
In-house billing systems have recently given the companies greater control over the
meter reading and billing activity. The systems also provide a sound platform for
internal and external reporting, providing greater transparency over service delivery
problems in both individual cases and for groups of customers. The issue now is to
act on this information, to prevent problems from recurring and to deal with the
legacy of past service delivery problems effectively.
There was a degree of non-compliance with some KPI information reported to AER
and we have made several recommendations designed to enhance reporting and
improve performance.
As we have suggested above there can also, sometimes, be too strong a focus on
meeting percentage targets, allowing acute problems to build up for individual
customers or groups of customers, who for some reason as regarded as not a
priority. Stronger consideration of the performance delivered to the „worst served
customers‟ would help ensure that no one receives an unacceptable level of
service and boost customer and regulatory confidence in reported performance
results and the efficacy of the customer service improvement programme. One
area where performance must still improve, and where we have observed few
positive plans to address problems, is credit management and the disconnection
process. Across the sector there has been a tendency to allow debt to build up
through inadequate follow up of small debts or successive no-access visits to
customers‟ premises by meter readers. This has resulted in large debt (both in
monetary terms and in relative terms compared with the individual customer‟s
circumstances) build up. When a firm meter reading is eventually obtained this
leads to payment difficulties. In some cases there may then be a need for a
payment plan to recover the debt; these are generally not handled well by the
companies.
The regulatory framework (LPCOP) is clear and requires that a customer‟s ability to
pay is taken into account when taking action to recover outstanding debts. There
is little evidence that the intent of this regulatory requirement is observed as a norm.
Instead companies appear to be making simple but arbitrary rules on initial
payments and on the permitted number of instalments, even in circumstances
where the company itself is at fault through not taking action earlier and where
debt may have built up over several years. The priority appears to be the
commercial aspects, rather than good customer service or regulatory compliance.
There are certainly too few payment plans agreed with customers. Little or no effort
is made to assess ability to pay, processes that exist are informal and not well
documented and, as a result, payment plans fail, leading to disconnection for non-
payment. We believe that all companies fail to meet their regulatory obligations in
this respect. Only Company I produced any substantive evidence that an
individual customer‟s ability to pay had been taken into account effectively.
In addition to the LPCOP there has also been a series of previous determinations by
the Authority that limits the recovery of electricity charges for customers to a
maximum of twelve months, in certain circumstances. On the basis of precedent
the Authority expects this to apply to all similar cases. We noted however that some
companies seem to believe that this precedent only applies if the customer submits
a formal complaint.
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Monitoring and reporting of complaints is generally handled reasonably well by the
companies and CHP compliance is satisfactory. However, some companies
continue to allow complaints to be handled by their MRBC contractors and there is
much less transparency and control over these. In addition, communication with
customers, particularly on acknowledgement and closure of complaints, is an area
that should be significantly improved.
The regulatory obligation covering the treatment of customers with special needs
has not been well applied. All companies have prepared a Special Needs Code
(SNC) and have now compiled a basic list of customers with special needs. There
was however, less evidence in relation to active delivery of the Code‟s obligations.
The exception is Company O, which we believe has an excellent end to end
process and internal procedures to ensure delivery. This could well be rolled out as
a country wide model. There was an argument put forward by Company I (and it
may be more widespread) that the concept of the electricity utilities supporting
special needs is not expected in Omani culture; however, it has been achieved in
one company and is a clear and longstanding regulatory requirement, not an
option.
Customers expect that requests for new connections are dealt with promptly and
that connections are made within a reasonable timeframe. New Connections were
generally found to be well handled with effective cooperation between the supply
and distribution businesses. However, the regulatory reporting of the time taken to
connect is often misleading and the intent of monitoring the true customer
experience is currently not being achieved. We have made some
recommendations to provide a more consistent and relevant reporting approach.
Customer communication during planned and unplanned outages is an aspect
that can always be improved and has a cross business dependency on distribution.
To differing degrees most companies are now working on this, utilising available
technology including interactive voice recording, SMS messages, their websites and
social media. Some are already at quite a sophisticated stage while others have
some way to go.
There are a number of sector wide issues that should be improved.
Recommendations to address these are summarised in section 1.2. Some are
improvements required by the companies, some will require action by the
companies‟ shareholder and some will require changes to reporting requirements
by AER.
It is disappointing to report that after ten years of regulation in the sector, some
basic requirements are still not in place. Of the five distribution licensees, all are
doing some things very well and others not so well. Ensuring compliance with
licence conditions and maintaining the right to operate their business should be the
principal concern of the licensees‟ boards and audit committees. However,
compliance assessment at this level tends not to be given the same attention as
commercial objectives. Although risk management processes may be in place to
identify risk and escalate issues, they tend not to give sufficient attention to
regulatory risk and, in particular the assurance of compliance with licence
obligations.
All companies are running potential breaches of Licence Conditions through the
approaches they take to considering a customer‟s individual ability to pay bills and
through a risk of discrimination (perhaps unintentional) by different treatments of
customers with debt and by application of their disconnection processes. All,
except for one, could potentially breach regulatory requirements on their obligation
to customers with Special Needs.
All companies face problems of differing degrees with outsourcing delivery of their
regulatory obligations to contractors and the effective management of contracts.
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These have to be addressed continually and improved. In three companies the
management teams are well placed to address this through a policy of continuous
improvement. Two companies, however, face particular challenges. Company O
has to replace an existing factoring contract, which has been in place in its current
form for around 20 years and this will demand a different relationship with suppliers
who may be appointed and will place on Company O the obligation to manage
meter readers employed by others. It may need to be accompanied by a
customer awareness campaign by Company O. Company I faces a major
challenge of reversing a history of mismanagement, including to a large extent
inadequate contractor management, as evidenced by recent quality assurance
exercises. Neither of these are small tasks.
1.2 Summary of Sector Wide Recommendations
Reference Recommendation Completion
Date
SR1
(Page 20)
That AER introduces an additional KPI - number of customers
currently disconnected (at each quarter end) for non-
payment.
To be
discussed
with AER
SR2
(Page 20)
That all companies, for each payment plan entered a
record a clear demonstration of considering the individual
customer‟s ability to pay.
To be
discussed
with AER
SR3
(Page 21)
That all companies to carry out an annual representative
sample of quality assurance check meter readings as part of
their on-going contract management procedure.
To be
discussed
with AER
SR4
(page 23)
That AER provides the companies with a standard template
which calculates the appropriate KPI information correctly
using raw data entered by the companies.
To be
discussed
with AER
SR5
(page 23)
That AER implements an additional KPI to reconcile the
differences between bills produced and the number of live
accounts.
To be
discussed
with AER
SR6
(page 24)
That AER implements an additional KPI “the number of
customers who have not had a firm meter reading in the last
twelve months”.
To be
discussed
with AER
SR7
(Page 26)
That AER puts in place a clear credit management policy
and effective procedures, amongst other things, to prevent
customers‟ debt building up to more than [6] times their
historic monthly account, regardless of the size of the
account.
To be
discussed
with AER
SR8
(Page 26)
That the introduction of prepayment meters is accelerated
across the whole country as a means of helping Customers
avoid this debt and that a Customer awareness campaign is
implemented to promote prepayment meters in cases of
hardship.
To be
discussed
with AER
SR9
(Page 27)
That the process of providing a customer with a main fuse to
reconnect their own supply after disconnection for non-
payment should be prohibited on commercial and safety
grounds.
To be
discussed
with AER
SR 10
(Page 31)
That three new KPIs related to connections replace the
existing return to AER.
Connections KPI-1 (applicable to all connection types). Time
to provide the customer with a substantive response to his
To be
discussed
with AER
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Reference Recommendation Completion
Date initial application. Standard: % response within 7 days for
applications below 1MW and within 90 days above 1MW1.
This is generally monitored already and should involve no
additional recording work by the licensees.
Connections KPI-2 (applicable to simple connections
requiring network extension only). Time to complete the
necessary connection works for a connection of below
1MW. This is generally not measured at present in a
regulatory capacity but will be from a contract
management perspective. It is the area most likely to result
in poor customer service and complaints and is currently
often invisible.
Connections KPI-3 (applicable to all connection types). Time
to provide the final connection from receipt of customer
payment. It is this final stage that is currently seen by
licensees as the regulatory requirement on which they have
to report. It is, however, the shortest, easiest to deliver, part
of the process that measures only the time taken after all
major issues and delays have been identified and resolved.
It is therefore not representative of the customer experience.
Table 1: Summary of Sector wide Recommendations
1 Quite separate from the reporting mechanism we believe that the increase from 7 days to 90 days is
too great for provision of a standard substantive response. We recommend that this should be brought
down to 30 days with a target of 90%, and explanation on individual cases that exceed this period.
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2 Introduction
2.1 About this report
This report summarises the outcome of the compliance assessment conducted
between May and September 2016 by energypeople limited with the staff of AER
Customer Affairs Directorate. It has been prepared to satisfy the requirement in the
terms of reference to provide ‘a concise overall summary report, identifying the
strengths and weaknesses of each licensee, together with appropriate
recommendations for actions…„
The Executive summary (section 1 above) and the remainder of this report have
been drafted to provide an ‘overall summary … to the Authority’s Members (if
required) and to the senior customer services managers of the licensees…’.2 For the
purposes of publication this report has been anonymised and the 5 Distribution and
Supply Licensees are referred to as Company D, I, S, C and O, with the MRBC
contractors referred to as Company X and Company Y. Certain specific
geographical locations have also been anonymised where they would reveal the
identity of the licensee.
In addition to these two requirements specified in the Request for Proposals (RfP), a
report for each licensee has also been prepared, which summarises the key issues
and provides supporting narrative of our assessment of the ’strengths and
weaknesses of each licensee’. These reports are intended only for AER and at AER‟s
discretion, the individual licensee.
2.2 Background
An assessment of the extent to which the supply and distribution licensees comply
with the customer service related conditions of their licences is important for a
range of reasons. Most important among these are: first, to understand how the
licence conditions are presently translated, applied into companies‟ policies and
practice and how customers experience the service provided by the five
companies; and second, in developing the regulatory framework to better protect
the interests of customers into the future.
The Authority has a duty to protect the interests of electricity customers and this is
delivered through conditions in the licences granted to the five companies. The
numbers given below relate to MIS licensees. RAECO and DPC licenses are
differently numbered.
The most immediately relevant to customer service are:
Licence condition 24 „…requires electricity Suppliers to effectively and
transparently resolve customer complaints in a timely manner „ (this is given
effect principally by companies preparing, publishing and implementing a
Complaint Handling Procedure.) This condition applies to RAECO through a
management undertaking to the Authority and is not a formal licence
requirement.
Licence conditions 28 „…duty to offer terms for Connection to the Licensee's
System‟ and 30 „Charges for Connection to and use of the Licensee's System‟.
(Supply terms, also known as Electricity Supply Agreement.)
Licence condition 41 „…setting out the methods for dealing with Customers who
incur obligations to pay for electricity supplied by the Licensee and who have
difficulty in discharging those obligations…‟ (Late Payment Code of Practice.)
2 RfP reference AER 01/2016, section 1.
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Licence condition 42 „…arrangements by which special services for customers
who are disabled, chronically sick, have limited income or of pensionable age,
can be made available, where appropriate …‟ (Special Needs Code of
Practice.)
Licence condition 43 „…setting out the ways in which the Licensee will make
available to Customers such guidance on the efficient use of electricity as will, in
the opinion of the Licensee, enable them to make informed judgments on
measures to improve the efficiency with which Customers use the electricity
supplied to them …‟ (Energy efficiency Code of Practice.).3
Licence condition 20 requires Licensees to prepare and adhere to guaranteed
and overall standards of performance. This is given effect through a series of KPIs
developed to accompany the present price control and is likely to be the
subject of further review by the Authority from 2018 (see below).
There are also certain overarching conditions, which should inform any
assessment of compliance. For example, condition 19 „Non-discrimination in
carrying out the Licensed Activities … the Licensee shall not create any undue
preference in favour of nor unduly discriminate against any Person or class of
Persons‟ and condition 44 „ Register of Customer Accounts… the Licensee shall
maintain an accurate register of all premises which are connected to its
system…‟.
As mentioned above, in addition to the specific requirements of the Codes, AER
requires the companies to provide quarterly reports against certain customer
service KPIs in accordance with the price control in place for the period 1 January
2015 to 31 December 2017.
For the next price control period, AER has indicated that there is a possibility that
performance against these KPIs may be translated into financial incentives or
penalties for the companies. Hence there is a need for certainty that the indicators
are the appropriate ones (i.e. that an improvement in an indicator improves the
customer experience); that there is clarity on the definition of these indicators (i.e.
that all companies are attempting to prepare and report the same information);
and confidence that the data generated from systems can be relied on as valid
and reliable, and where necessary, audited.
In what follows we set out the approach and methodology developed and then
adopted to conduct the compliance assessment and identify strengths and
weaknesses in customer service policy and delivery covered by the licence
conditions. The approach to the study is described in section 3. The methodology is
explained in section 4 with the criteria by which each licensee was assessed set out
in detail in appendices 7, 8 and 9. The key findings from the study for the
companies as a whole are set out in section 5. In section 6 the compliance
assessment is presented - the findings for each company are set out in a series of
charts and diagrams.
2.3 Scope
The objective was to conduct a compliance assessment and this has been our
focus. However, it is perhaps inevitable that we do, on occasion, go beyond a strict
concentration on compliance to reflect on more general matters and the service
experienced by customers of the five companies. To give a simple example a
company may be compliant with licence condition 24 in that the evidence
suggests it has a clear, well communicated complaints handling procedure, records
and reports complaints received accurately and handles complaints efficiently and
courteously. If however, it has a high number of complaints relative to others -
3 The numbering and extracts are taken from a MIS licence but all licences carry the same import.
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which is attributable to a particular source or sources revealed by the audit - this
may be worthy of comment. Observations, which therefore go beyond a strict
assessment of compliance, are also noted as we believe they will provide a further
level of understanding.
2.4 Acknowledgement
We are grateful to the five companies4 for their help in providing information and
arranging to meet us, often at short notice, when there were pressing operational
matters to be dealt with. They generally approached the task with enthusiasm and
a degree of openness that was conducive to sector wide learning and
improvement.
The compliance assessment was conducted by a team which comprised officers
from AER and the energypeople team. The input of AER staff was invaluable
throughout in ensuring that the assessment was set in an appropriate context, which
took full account of customer feedback received directly by the Authority.
Specifically, AER staff followed through example cases and conducted sample
discussions with customers about their experience of customer service. This report
was, however, drafted by energypeople and responsibility for errors and omissions
remains with us.
It is important to emphasise that the assessment has been the companies‟
compliance with their licence conditions and not about the individual staff
members. During the visits to and discussions with companies, there were staff who
demonstrated commitment, enthusiasm and a real dedication to customer service.
It is also important to say that compliance is not the same as expertise in customer
service and the capacity to solve problems. We encountered staff who found ways
to innovate and improve their work and the service offered to customers.
4 Throughout the report, the terms licensee and company are used interchangeably unless otherwise
specified.
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3 Approach
The approach to conducting the assessment is shown in the diagram.
Figure 1 Approach to the compliance assessment
More detail on each stage follows below.
3.1 Phase 1 - Overview visits
The five distribution and supply licensees were visited by combined teams of
energypeople and Authority staff to gain an overview of each of the companies‟
positions with regard to policies, procedures, and collection and management of
information required when fulfilling their licence obligations. To support a standard
approach across all licensees an audit workbook was prepared; this was used as a
script and recording template for all companies. A copy of this template is
included as Appendix 1 to this report. At the end of each visit, informal „private‟
feedback was provided to the senior team at each company. This phase
concluded with a workshop for Authority staff, which reviewed the process
adopted, the audit outcomes for each of the five companies, lessons learned and
preparation for the next phase.
3.2 Phase 2 – Detailed reviews of licence compliance
Phase 2 visits were preceded by a detailed information request from AER to the
companies, which enabled a focus on specific areas of concern about
compliance.
These visits focussed on but were not limited to, meter reading (that KPI data
provided by companies matched service provider records, understanding DLP
issues and reporting); Late Payment Code of Practice (and supporting ability to pay
guidelines and disconnection policy and practice); complaint handing (recording,
timeliness and quality of response); connections to the network (processes, time
taken and KPI reporting); special needs customers (verification of the register and
how support is delivered); communications with customers before and during
outages; and the quality of front line advice available to customers.
During this phase, the AER team and energypeople reviewed the findings and
developed criteria by which the companies were assessed, covering both the areas
set out in the ToR and the specifics concerning particular licence conditions and
codes.
3.3 Phase 3 - Review, report and provide feedback
This phase was designed to ensure the initial assessments were thoroughly reviewed
and findings consolidated. Feedback was provided to the companies and reports
prepared for the Authority‟s officers and members.
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4 Methodology
4.1 Assessment criteria – Themes in the ToR
During the visits, we looked at a number of distinct areas for compliance assessment
under the six main headings, set out in the Terms of Reference. In summary these
are that in the companies:
The Regulatory framework is sufficiently well understood … staff awareness …
training;
There are clear business owners in relation to the regulatory obligations;
Risk management processes in relation to the regulatory obligations;
Reporting systems in place to enable monitoring by senior management;
No policies or guidelines which contradict regulatory obligations; and
Contracts and SLAs which … enable Companies to meet their regulatory
obligations.
In Appendix 2 we summarise the criteria by which Companies have been assessed.
On a simple, five point scale, the assessed level of compliance is an aggregation of
evidence to give an overall assessment, not a statement which describes precisely
a company‟s actual level of against each the detailed list included for each of the
six criteria.
An overview of the companies‟ assessed level of compliance is presented in section
5.2 of this report.
4.2 Assessment criteria – Detailed Licence and Code Compliance
During the visits, and especially during phase 2, we also looked more specifically at
areas of concern, including aspects of meter reading, the Codes of Practice and
Procedures (this report will refer to these generically as Codes of Practice) and their
application, KPI reporting and related compliance issues. The eight headings,
which cover this analysis, are as follows:
Meter reading, especially data verification
Meter reading, especially DLP problems
Late payment code of practice – ability to pay guidelines and disconnection
Customer Complaint Handling Procedures
New Connections to the network
Special needs customers
Outage management and communication with customers
Quality of front line advice
All companies have Codes of Practice in place, which have been approved by the
Authority. They all therefore provide a policy framework, which at a basic level
complies with the relevant licence conditions. They contain statements of the
companies‟ intended processes to ensure, for example, complaints are handled
appropriately, customers who encounter difficulty paying are dealt with fairly and
support is provided to customers with special needs. Translation of these Codes into
customer facing actions and behaviours is, however, variable between companies
and between Codes within companies and there were observed shortcomings.
Criteria were developed therefore, as shown in Appendix 3 to test the Codes
themselves and their implementation in everyday activities. They include a general
description, followed by more detail for each of the eight areas of concern that
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were investigated, which enable companies‟ policy and practice to be
represented on the scale. These differentiate between levels using a number of
examples of good and poor practice.
5 Findings
5.1 Phase 1 Overview Assessment
5.1.1 Understanding of Regulatory Framework
Phase 1 of the compliance assessment gave some assurance that all of the
licensees had in place Codes and/or statements for each of the licence conditions.
Phase 1 assessments therefore had positive aspects in all companies. However, in
all cases omissions and shortcomings were identified. More detailed investigation
revealed that there were variations in the extent to which the Codes were
communicated internally and to customers and the range of channels used; the
ease of use and availability of the Codes; and the quality of delivery of the service
set out in the Codes.
The issues range from minor inconsistencies in presentation (a Code not quoting the
latest toll free number for the company‟s Contact Centre, referring instead to
regular office numbers) through to what amounted to a potential breach against
the special needs obligation (although having a Code, the company did not retain
a readily accessible register of customers with special needs)5.
5.1.2 Well defined business owners for each Regulatory Obligation
An important and early step in the implementation of the Blueprint was to put in
place the accountable managers, team leaders and staff in an organisation
structure designed to deliver efficient customer service. All of the companies now
have structures in place based on the Blueprint recommendations; most have some
vacancies within the new structures and there are examples of variations to the
model. We do not comment on the efficacy of these variations but do confirm that
responsibilities appear to be clear and unambiguous.
In all cases there is a manager with overall responsibility for customer service
supported by a team with individuals responsible for the following functions:
Customer affairs, including the Contact Centre, dealing with complaints etc;
Meter reading and billing;
Data management;
Collection; and
Performance review.
We did, however, observe a significant dependence on the performance manager
role, potentially easing accountability on functional managers. Some of the
performance managers are new to the electricity supply industry bringing new
business focus to a traditional utility background. However, licensees must be
cautious not to over emphasise the commercial aspects at the expense of the
regulatory obligations of a monopoly utility, even if those obligations do not always
appear to be good business in the short term. It is important that all customers
receive an acceptable level of service and that acceptable or even good service
for the majority is not contrasted with very poor service for the few.
5 A matter which the company addressed between phase 1, when no central and accessible list was
available and phase 2, when rapid progress had been made to establish and communicate such a
register.
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During our interviews with the respective management teams, each of the
companies was able to identify individual business owners responsible for each of
the regulatory obligations and business owners were generally well defined, though
two companies still had some changes to implement. For example, the manager
responsible for customer affairs generally assumed principal responsibility for: the
Customer Complaint Handing Procedures; the Efficient Use of Electricity Code of
Practice; and the Special Needs Code of Practice, and the manager responsible
for Collection assumed responsibility for the Late Payment Code of Practice.
The effective operation of the organisation within a particular company relies on
good communication and cooperation between the various activities within the
supply business and in most cases this was found to be working reasonably well.
There are several key customer service activities, which are partly delivered by the
supply business and partly delivered by the distribution business - for example,
supply is responsible for most aspects of communication with customers for new
connections but most of the actual delivery is provided by distribution. Again, in
most cases we found communication channels to be effective, if cumbersome with
multiple hand offs and no significant customer facing issues arising from any „blurred
responsibilities‟. There was, however, scope for efficiency improvement in all
companies by reviewing the interdepartmental handovers in the process.
5.1.3 Sufficient Risk Management on Regulatory Obligations
Phase 1 indicated that companies had, to varying degrees of sophistication,
processes in place to identify risk, some with appropriate levels of escalation
according to severity. Effective management and mitigation of risk were variable.
In terms of regulatory risk there appear to be three main areas for attention. The first
concerns the fact that all companies are managing the implementation of multiple
IT systems, whether completely new systems or substantial upgrades. Although we
did not audit the rigour with which this implementation is being managed,
companies did have project management processes in place to protect the
integrity of regulatory compliance and maintain basic service levels. One company
itself, recognised this multiple change as a major risk. An associated and ongoing
risk noted in all companies - some more than others - was the over optimistic
expectation of what the new systems will deliver on implementation. We expect
there to be a significant implementation period before full benefits are realised.
The second concerns the reliance on the service provider to deliver MRBC. This is an
area of rapid change. New, unbundled (and geographically defined) contracts
are being prepared (which generally facilitate some competition and tighten the
risk/reward arrangements to enable greater control) and these are being let (on a
phased basis) as existing contracts end. There are also new systems under
development and implementation, which enable a reduced dependency on the
service provider and provide greater control, such as the introduction of new hand-
held devices for meter readers and bill delivery staff.
In the immediate future, MMR promises greater certainty and AMR a fundamental
change in work processes, which will have the effect of eliminating much work and
bringing other activities in house.
The transition to new contracts and potentially new service providers must be given
appropriate attention at the highest level in companies to gain the expected
improvements and independence from service providers in managing regulatory
obligations.
The third, and perhaps the most fundamental risk for the licensees is the risk of losing
sight of their regulatory obligations in favour of their commercial drivers. There was
evidence of this among some managers and little evidence that regulatory risks are
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regularly assessed by Board or audit committees (which might be expected to go
some way towards redressing the imbalance).
In the immediate term however, there are regulatory risks associated with the
current contractual arrangements with contractors. For example, Company O has
a factoring arrangement with its contractor, Company Y, which provides a
complete meter reading, billing and collection service. Under the arrangement
Company Y is entirely responsible for account collection and its commercial
incentives are not necessarily aligned with delivery of Company O‟s regulatory
obligations under the Late Payment Code of Practice. The contract is due to expire
early in 2017 and in the meantime the Company O team relies too heavily on the
contractor„s goodwill to deal with customers in accordance with its codes, for
example to agree suitable payment arrangements. We believe that this
arrangement constitutes a very serious regulatory risk that the company does not
appear to recognise fully.
There are several risks associated with relying on contractors to deliver important
customer facing activities such as meter reading, bill distribution and account
collection, unless carefully managed. As part of a loss reduction initiative
undertaken in one company, follow up meter readings by the company‟s own staff
identified a large proportion of readings that had been submitted incorrectly by its
contractor. This is at best incompetence or at worst indicative of systematic fraud or
corruption. In addition to the obvious contractual issues, a result is that licensees are
likely to be in breach of regulatory requirements and many customers will have
received poor service through the delivery of inaccurate bills. The evidence
gathered suggests this is an area for urgent review.
5.1.4 Adequate IT systems for internal reporting
The companies are at various stages in implementing the Customer Service
Blueprint recommendations. All companies, with the exception of Company O,
now have in house billing systems which have given them greater control over the
meter reading and billing activity and also a sound platform for internal and
external reporting. The billing systems can be used to provide information for
reliable performance reporting, for example in assessing how many meter readings
have been obtained and how many bills are generated etc. This is useful
information but in all companies we were left with the impression that certain
activities were managed almost to achieve specific KPI targets. For example all
were keen to manage the percentage of customers for which the company
obtains firm meter readings each month, less so in addressing the worst served
customers who had not received an accurate bill for many months, or in some
cases years.
Whilst this is a very useful indicator (particularly in supervising contractors‟
performance) it needs to be supported by other measures to ensure that all
customers receive an acceptable service. The use of overall percentage
performance measures has, in our opinion, given companies a belief that they have
performed successfully, which may not be justified and may not reflect customer
opinion. For example, one company reports a high percentage for obtaining firm
meter readings each month but its records show that it is frequently the same
customers whose meters are not read each month - there were more than 300
customers who had not had a meter reading since 1997 (some nineteen years).
In addition to managing the overall volume, the companies vary as to how
effectively they monitor and manage their “worst served customers”. In our opinion,
there was a degree of complacency about these issues in all companies.
Explanations offered were along the lines of: „as we receive no complaints about
the issue everything must be ok‟, or „mistakes will always be made‟. This mind set is
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not, in our view, appropriate in a modern customer-focussed organisation with a
monopoly position.
The sector is undergoing a major transformation in the way it delivers its principal
customer services functions, particularly with the introduction of new systems and
organisation, and the evolving contractual relationships with external service
providers. Rather than put proper processes in place to resolve specific issue there
appeared to be a general feeling that new systems as they are introduced will solve
all problems - whether MMR, AMR, CRM or the next billing system. The new systems
will help but the day to day delivery of customer service activities require careful
management and monitoring by the companies, irrespective of the systems that
are planned. We detect a huge expectation that new information systems will
resolve all current problems. They will not. New systems will help enormously but not
without the huge amount of work that will be required for data transfer and
dedicated on going management.
Despite disconnection for non-payment being frequently used by all the
companies, we were unable to obtain the number of customers currently without
supply because of non-payment. In our estimation this is a valuable indicator -
which should not need to rely on sophisticated IT systems to be extracted.
SR1. Subject to more detailed consultation, we recommend that Number of
customers disconnected for non-payment at the quarter end is included as part of
AER‟s KPI reporting pack.
5.1.5 No conflicting instructions
During our audit visits we did not identify any instructions that are specifically
contrary to the companies‟ regulatory obligations. However, there are several
areas of potential conflict, such as practice in relation to account collection where
the companies‟ commercial objectives in securing prompt payment may not be
entirely consistent with the full application of the Late Payment Code of Practice
and may not be consistently applied to similar customers. Under the code, the
companies agree payment arrangements with customers but these are typically
over a fairly short time period with a requirement for a large initial payment and
from the sample cases studied, do not in most cases take account of the
customers‟ ability to pay as required under the Code. However, there was
evidence in Company I of cases where proper investigation, to the extent that is
achievable within the bounds of confidentiality, had been carried out.
SR2. We recommend that all companies, for each payment plan entered a clear
demonstration of considering the individual customer‟s ability to pay is recorded
and that a credit management policy is developed that ensures consistency in
relation to payment plans and the implementation of the disconnection sanction
(and helps prevent debt build-up
5.1.6 Adequacy of SLAs and Contracts
Historically all the companies have used contractors for the provision of their meter
reading, billing and collection activities. The sector has embarked on a strategy to
reduce reliance on third party contractors and bring certain key services in-house
ensuring that companies manage their own regulatory obligations. The companies
are at various stages in the transition, but all with the exception of Company O now
have their own billing systems. In the medium term meter reading, bill production
and delivery will remain outsourced. New contracts will be structured to enable
different suppliers to provide services split by activity or geography - rather than for
the provision of a complete meter reading billing and cash collection service.
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In this regard, Company O is a special case. Company O has a legacy factoring
type contract under which the contractor, Company Y, bills customers and collects
payments and pays Company O an amount calculated on the billing total less its
commission. The arrangement has been in place for several years and is due to
expire early in 2017. Company Y‟s obligations to Company O under the contract
are not directly aligned with Company O‟s regulatory obligations and there must be
a significant risk that the actions of Company Y could place Company O in breach
of its licence. For example, Company Y claims to make payment arrangement with
customers in line with the Late Payment Code of Practice, but only as a goodwill
measure towards Company O.
There is no contractual obligation for Company Y to deliver this specific Code and
its commercial drivers would tend to prompt a harder approach with late payers
than that described in the code. Similarly, Company Y controls the meter reading
and disconnection action it takes and there can be no guarantee that it treats all
customers consistently, with a risk to Company O of customer discrimination. For
example, if Company Y decided to neglect some of the more remote customers
because they are costly to deal with it is unlikely that this would be identified by
Company O, though they acknowledge (and seem to accept) that it is likely to
happen. Although Company O monitors Company Y‟s performance and has
regular meetings with them, much of the information that is used to evaluate
performance is provided by Company Y. The structure of future contracts with
service providers clearly needs to be more aligned with the company‟s commercial
objectives and regulatory obligations.
The other companies have their own billing systems but continue to rely on
contractors for the provision of meter reading, bill production and delivery and cash
collection. Contract terms are based on fees for the delivery of the specified
services.
The contracts are similar in nature and each has different performance based
incentive measures based on performance targets. In some cases the contractor
can earn an incentive payment for exceeding the target performance and in some
cases the contractor suffers a penalty payment if the target is not reached. Table
17 in Appendix 4 summarises the Incentive Based Performance payment
arrangements under the existing contracts.
In a well-designed contract the incentive mechanism would be directly aligned
with the principal objectives of the customer/client. Thus in a meter reading
contract, for example, it would be expected that the contract and its performance
incentives would be designed to ensure that: all customers were visited for a meter
reading at the appropriate frequency; meter readings were accurately taken and
submitted for billing; there was adequate control to ensure appropriate follow up of
cases where access was not possible; and that problems with meters were
accurately identified and promptly reported.
While more measures may mean greater effort by the company to monitor the
contractors‟ performance, it is likely that the suite of measures used by MZEC is more
suited to ensuring effective performance than those presently applied in the other
companies. (For example the specific measure designed to ensure customers have
a meter reading at least once every three months is a useful way to deal with
successive no access cases – referred to as DLP „door locked permanently‟ in
industry jargon).
Poor quality meter reading appears to be the single biggest reason for customers‟
dissatisfaction and cause for complaints. The nature of the meter reading activity
means that it is difficult to supervise but monitoring is important to avoid abuse and
poor service. The billing systems in place in most companies now have validation
routines that now make it easier for the licensees‟ staff to monitor performance and
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billing registers provide the raw data to analyse some aspects of performance.
However, the recent exercise undertaken by Company I in checking the meter
reading performance of its contractor in which many meter reading errors were
identified demonstrates the need for adequate monitoring and independent
quality checks.
SR3. We recommend that all companies should carry out a representative sample
of quality assurance check meter readings as part of their on-going contract
management procedure.
All of the companies had been preparing for the separation of supply and
distribution activities – known as business separation. Service Level Agreements
between the departments had been prepared, though these were in various states
of readiness and detail. Some were prepared, signed and operational; others were
drafted but requiring finalisation and sign off. Any specific issues revealed during
the assessment are mentioned under the subject heading: for example outage
management, connections to the network, and dealing with special needs
customers. There were few interface issues of significance and AER may take
comfort from the fact that business separation and the implementation of SLAs are
being addressed and will be followed through as part of Blueprint.
5.1.7 Phase 1 Overview Assessment All Company Comparison
The result of applying the criteria to the information and analysis of the companies is
summarised in Table 2 below.
Company
O
Company
Y
Company
S
Company
D
Company
I
Understanding of
Regulatory Framework 4 3 5 3 5
Well defined business
owners for each Regulatory
Obligation
5 3 5 5 3
Sufficient Risk Management
on Regulatory Obligations 1 1 3 3 3
Adequate IT systems for
internal reporting 2 2 3 3 1
No conflicting instructions 2 3 3 3 3
SLAs and Contracts 1 1 3 1 3
Table 2: Phase 1 Overview Compliance - All Company Comparison
(A score of 5 is very good, 3 at an adequate level, 1 is poor, 2 and 4 are
intermediate levels.)
5.2 Detailed licence and code compliance
5.2.1 Meter reading (Verification that KPI data matches contractor records)
AER has developed a suite of KPIs against which the companies are required to
report. These should provide a useful indication as to the performance of various
customer service activities but it is important that they are prepared and presented
by the companies on a consistent basis if they are to provide any useful comparison
data across companies and/or over time.
The Meter Reading KPIs MR1 to MR3 report the percentage of customers whose
meters are read according to the schedule for different classes of customers. We
were generally able to verify the accuracy of the KPI information provided for the
quarter ended March 2016. All the companies extract raw data from their monthly
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billing registers (either their in house system or as extracted from a contractor‟s
system) to calculate the percentages and with the exception of Company C were
able to demonstrate the accuracy of the data. In Company C‟s case, a
recalculation of the KPI data showed a slightly better performance than had been
provided to AER. We recommend that all companies should be required to retain a
verifiable „audit trail‟ of KPI data submitted to AER to be available for subsequent
review if required,
The definition provided by AER refers to customers whose meters are read by the
company (or its agents) in each month. All the companies include readings
provided by customers within their counts on the basis that photographs of meters
are required and the readings submitted can therefore be considered firm. Whilst
we do not think that these fall within AER‟s definition, the KPI data provided is on a
broadly consistent basis.
MR4 is defined as the percentage of customers whose meters are not read at all by
the company (or its agents) in any month in the quarter. While this definition
appears fairly clear it has caused a degree of confusion and inconsistency of
application across the companies. Company C were reporting the average of the
percentage not read in each of the months for the quarter (and so their reported
performance was worse than the actual performance), while Company D did not
report.
SR4. We recommend that to ensure consistency in future AER provides the
companies with a standard template which calculates the appropriate KPI
information correctly using raw data entered by the companies. A sample
spreadsheet for this purpose is provided in Appendix 5.
The second set of KPIs relate to billing information, which is less easy to validate. The
number of customer bills printed (B1) and the number of bills delivered (B2) were in
all cases numbers provided by the contractor. It was generally believed that the
contractor delivered all bills that were printed, although in one company the
number of bills claimed as delivered during the month was approximately 2,000 less
than the number of bills printed. The company did not have an explanation for this
and so it is likely that a significant number of customers did not receive their bills.
The number of bills printed is generally less than the number of live accounts and all
companies were able to provide assurance that bills were generated for all
customers that should receive them. At another company, for example, there was
a difference of approximately 29,000 between the number of bills reported in any
month and the number of recorded accounts, which was explained by demolished
premises that were still recorded as live and required tidying up. In addition some
companies currently do not raise zero value bills where there is no consumption and
this partly explains the differences.
SR5. Within each of the companies there should be some overall controls to ensure
that all relevant customers receive bills and it is recommended that the AER billing
KPIs should include a high level reconciliation between bills produced and the
number of live accounts (i.e. any differences should be categorised)
5.2.2 Meter reading (Verification of DLP problems)
All the companies have adopted monthly billing as the norm and attempt to read
customers‟ meters once each month (with the exception that Company D moved
to bi-monthly meter reading during the period of this assessment). Failure to gain
access to read meters on occasion is not normally a real cause for concern,
provided that estimates are reasonable and the meter is inspected by the
company (or its agents) periodically. However, if this occurs on successive billing
cycles the gap between actual consumption and the amount billed increases, so
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that when a reading is eventually obtained the bill prepared is often very large and
discrepancies are exaggerated. There were examples reviewed at each of the
companies where large bills have been prepared following a succession of
estimates or zero accounts. This is frequently a cause of complaint, particularly
when the customer is faced with action to collect an amount that they cannot
comfortably afford.
All companies (and their contractors) attempt to obtain firm meter readings each
month with various degrees of rigour and success. In cases where the meter reader
is unable to gain access, notices are left for the customer to contact the company
(or its contractor) to arrange a meter reading appointment or to provide a
customer reading. Despite return visits there are many cases where the companies
are unable to obtain their own readings. The meter readers record these as DLP to
indicate that they were unable to gain access.
As indicated above, there is a tendency by the companies to focus on overall
percentages in terms of meter reading success rates rather than on individual
customers that have not had a reading for some time. There were significant
numbers of cases in each of the companies showing a series of DLP recordings over
many months. There was little evidence available showing what actions had been
taken to gain access to meters in these cases and the follow up attempts by the
companies varied.
Whilst we acknowledge the difficulties associated with following up these cases,
particularly with seasonal occupied premises and dealing with customers who are
unwilling to communicate or to allow access to their premises, we believe that all
companies could do more to proactively manage the situation and to demonstrate
to the customer and regulator that they have taken all reasonable steps to inspect
their meters and prevent debt build-up.
SR6. As discussed above, we recommend that AER reporting pack includes an
additional measure “the number of customers who have not had a firm meter
reading in the last twelve months”.
The billing systems in use are capable of producing estimated bills when readings
are not obtained, usually based on previous consumption. However, in some
companies the practice is to generate a zero bill if DLP is recorded on a defined
number of successive occasions. For example, at Company S, if DLP is recorded on
one occasion an estimated account is prepared, on the second occasion an
estimated account is also prepared but on the third occasion a zero account is
prepared. This may be a reasonable approach when there is clearly no evidence
of electricity consumption (for example in seasonally occupied premises) but for the
majority of customers we believe it to be inappropriate. While receiving an
estimated bill might encourage a customer to contact the company to arrange a
firm reading, receiving a zero bill would not have the same effect. Indeed, many
customers would see an immediate advantage if the meter reader could not
obtain access.
We have seen a number of examples where this policy has resulted in very large bills
being raised when readings were obtained, resulting in dissatisfied customers,
complaints, customers facing difficulties in making payments and also writing off
significant revenue when the billed consumption extends beyond twelve months.
Following on from our review at the companies‟ offices, AER staff telephoned a
sample of 25 customers for each company with a high number of recorded DLPs. In
the majority of cases the customers explained that meters were located outside
their properties and there should therefore have been no reason why firm meter
readings had not been obtained, causing real doubt about the validity of the DLP
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coding provided by the contractors. This is supported by the Company I audit of
meter readings taken by its contractor.
Many customers also claimed that they had not received notices from the
companies about the failure to obtain access to read meters. This is clearly an area
that needs better control in all companies and should be incorporated in a clear
and consistent credit management policy designed to prevent debt build-up and
complementing the Late Payment Code of Practice (see recommendations SR2
and SR7).
5.2.3 Late Payment Code of Practice (Ability to pay guidelines)
Each of the companies has published a Late Payment Code of Practice in which
they undertake to allow customers facing difficulties with paying their bills to pay off
their debts in accordance with their ability to pay. We have, however, seen very
little evidence that this has been put into practice. In reviewing a sample of
payment plans at each company, it was only at Company I that evidence of
customers‟ ability to pay (Social Security records) had been obtained and retained.
Proving inability to pay is a concept difficult to apply and local staff in particular
make subjective judgements based on their knowledge of their customers. This
results in inconsistent treatment and is likely to mean that the companies could be in
breach of their non-discrimination licence obligation.
The companies generally had broad guidelines as to what agreements could be
made, with different approval levels given allocated to front line staff, Contact
Centre staff and managers etc. However, the general guidelines are without
exception very onerous and require customers to make a large initial payment
followed by significant instalments over a short time period. The evidence suggests
that many of the agreements entered into fail and the customers are then subject
to the disconnection policy. It should be clear at the outset that a significant
proportion of these plans are set to fail based on the customer‟s previous difficulties
in making payments.
In many cases customers are faced with large bills that they cannot afford, in part
due to a failure by the company, for example issuing a large bill following a series of
zero accounts or under-estimated bills because of failure to obtain access to
premises. Even in these situations the companies did not generally seem to adopt
an appropriately sympathetic approach to customers‟ needs and were more
concerned about their internal accounting rules (there was some anecdotal
evidence that payment plans of more than 12 months require some of the debt to
be written off).
As a general rule it is better to accept payment of a customer‟s current
consumption plus a very small amount towards any debt, rather than to arrange a
plan that the customer cannot afford. In some cases this could mean that it would
take several years to clear some debts. It is recommended that all companies
review their guidelines for the agreement of instalment plans to ensure they are
consistent with the LPCOP.
In all of the companies we saw examples of the failure to pay fairly small monthly
accounts not being effectively followed up, often because each of the amounts
outstanding was less than a threshold for disconnection (despite the customer
receiving disconnection notices). In these cases debts accumulated to a point
where the customer was later faced with actual disconnection or agreeing an
instalment plan which they could not afford. The inconsistent approach to
disconnecting customers for non-payment (discussed in the following section) has
failed to provide customers with any clarity as to the consequences of non-
payment until too late. Whilst customers have a duty to pay their bills the
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companies have a responsibility to prevent customers‟ debts building up to
unmanageable levels.
All companies were asked by AER to provide a list of all payment arrangements
entered into since June 2015 along with details of the debt, the number of
instalments agreed and whether the payment arrangement was successful. The
quality of the responses was not, generally, to a high standard with incomplete data
and information that was inconsistent with the Late Payment Code of Practice
returns submitted to AER.
Our overall conclusion is that this is an area not effectively controlled by the
companies. Table 3 below shows the number of agreements shown on the returns
submitted by the companies and for comparison, the number of agreements shown
of the LPCOP return.
Company
Number of payment
arrangements entered into since
June 2015
Number of payment arrangements
per LPCOP Return for Quarter
ending March 2016
Number Number per
10,000 accounts Number
Number per
10,000 accounts
Company O 199 21 No reliable data available
Company I 474 24 2,840 143
Company S 3,448 94 810 22
Company D 2,765 89 767 25
Company C 25 8 1 0
Table 3: Comparison of Payment Arrangements
Despite the obvious inconsistencies in some of the information there is a variation
across the companies as to the use of payment arrangements to collect debt.
Even allowing for the smaller number of customers at Company C, the reported
numbers suggest that this is not a situation being promoted by the company.
At Company O, under its contractual arrangement, Company Y is currently
responsible for account collection. Company O has published its Late Payment
Code of Practice and has widely publicised it. However, whilst Company O has the
licence obligation, Company Y makes payment arrangements with customers as a
matter of goodwill for Company O as there is no provision in the contract. Under
this arrangement, Company O cannot provide any assurance that it is operating in
accordance with its own Code. The contract is due to expire at the end of the year
but in the meantime there is a very real regulatory risk facing the company.
Prepayment metering is not widely used in Oman at present with the exception of
Company D but provides an excellent solution to the recovery of debts, particularly
for those on low incomes. Compliance with the Code in Company D is much more
straightforward as any customers who wish to make an instalment plan can, as a
last resort, elect to have a prepayment meter, with debt recovery permitted over
two years. We believe that this arrangement better ensures compliance with the
Code and helps those on low incomes. It is recommended that the prepayment
initiative pioneered by Company D is extended to all companies. This is planned
but should be implemented as soon as possible.
SR7. We recommend that AER puts in place a requirement on all companies to
prepare and implement an effective credit management policy designed,
amongst other things, to obtain access to inspect customers‟ meters and prevent
customers‟ debt building up to more than 6 times their historic monthly account,
regardless of the size of the account.
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SR8. We also recommend that the implementation of prepayment meters is
accelerated across the whole country as a means of helping Customers avid this
debt and that a Customer awareness campaign should be implemented to
promote prepayment meters in cases of hardship.
5.2.4 Late Payment Code of Practice (Disconnection Notices)
The threat of disconnection is the main weapon used by all the companies to follow
up overdue bills. All were able to clearly outline the process leading up to
disconnection, which invariably involved the issue of reminders, final notices and
disconnection orders.
There are significant numbers of customers in each of the companies who are
disconnected. The companies were requested to provide details of customers
disconnected for non-payment during March 2016 and the numbers are
summarised in the table below. The table also shows the numbers of customers
disconnected during the quarter ended March 2016 as entered on the LPCOP
submissions.
Company
Customers disconnected for non-
payment March 2016
Number of customers
disconnected for non-payment
per LPCOP Return for Quarter
ending March 2016
Number
Number per
10,000
accounts
Number
Number per
10,000
accounts
Company O 678 73 2,213 239
Company I 65 3 2,545 129
Company S 2,405 66 5,852 160
Company D 3,415 110 12,345 398
Company C 33 10 73 22
Table 4: Customers Disconnected for Non-Payment
Again, despite some inconsistencies in the information provided, there are clearly
large numbers of customers who are disconnected. Nevertheless, although the
process is very clear there are still a great many customers who would be
disconnected according to the process and who receive disconnection notices,
sometimes on a regular basis, but who are not disconnected. There are several
reasons for this. In some cases disconnection action is not taken because the
amount to collect is relatively small, in others internal or external (contractor)
resource constraints means that action is not pursued, or disconnection is not
possible because of difficulties in obtaining access to the meter. This does result in
an inconsistent approach to disconnection and many customers have accrued
significant debts without being disconnected whilst others with smaller debts have
been disconnected. This potentially means that all companies are in breach of the
anti-discrimination licence condition. There is clear need for each of the
companies to expand their credit management and disconnection policies to
clarify what should happen and demonstrate that their processes are non-
discriminatory.
As discussed in the previous section, the companies are in part responsible for a
serious collection problem by allowing debts to accumulate to unmanageable
levels. In many cases small monthly bills, which remained unpaid were not
adequately followed up and when the customers were eventually faced with
disconnection they could not afford the large debt that had built up. All
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companies could do more to prevent debt build up, whether implementing the
disconnection process for small amounts or making greater use of prepayment
metering. (See recommendations SR2 and SR7).
Many customers disconnected for non-payment are reconnected within a very
short time scale after being disconnected, frequently on the same day. Company
O does not raise disconnection or reconnection fees if the outstanding amount is
settled within five days and so many customers wait until they are disconnected
before paying. This is clearly inefficient and if the company were to raise the
published fees, as the other companies do, it should encourage more customers to
pay sooner.
Following on from our review at the companies‟ offices, AER staff telephoned a
sample of customers for each company which had been disconnected for non-
payment. Several customers claimed that they had not received any notification in
advance but were generally satisfied that they were promptly reconnected when
they settled their outstanding accounts.
At Company O it appears to be general practice for the contractor (Company Y)
to provide customers with a main fuse once their accounts have been settled and
the customers reconnect themselves.
SR9. Apart from the commercial considerations of this practice, there is an
important safety consideration and we strongly recommend that main
reconnections should only be performed by suitably trained representatives of the
company.
5.2.5 Complaint Handling Procedure (Quality of response)
All companies have published a Complaint Handling Procedure and have
implemented the Blueprint recommendation to appoint a complaints coordinator,
or have nominated a post holder to perform this function. This is an area where the
KPI functions has the potential to perform effectively in that all companies (with the
exception of Company O) record the opening of a complaint on CRM and also its
closure. This is an area in which reporting (the principal KPI requires measurement of
the time taken to resolve a complaint) is therefore transparent and open to
straightforward auditing.
Evidence suggests however that there are issues for consideration, the main ones
being:
Definition. Companies vary in the way in which they define a complaint – from
allowing the Contact Centre agent or service centre/branch officer to decide,
on the basis of perceived customer dissatisfaction, what to record on CRM,
through to a tightly defined definition of a complaint as an allegation of error on
the company‟s part. For an individual company looking at trends over time and
the scope for improvement, this is not an issue as consistency year on year is
what matters when tracking performance and the key issue is that each
customer is satisfied that his issue or complaint has been satisfactorily addressed
and that the company has a process in place to analyse and learn from service
delivery failures.
Comprehensiveness of reporting. There is a concern that not all complaints may
be captured. Internally the implementation of the Blueprint structure - which
means that all complaints are registered with the Contact Centre and resolution
is managed/coordinated by them - is improving recording and monitoring. On
our visits, evidence suggests that Company D are consolidating the role of the
Contact Centre most firmly and were moving to the separation of supply and
distribution calls into separate units. Others were making similar progress.
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Anecdotal evidence suggests however that the service provider may, in some
instances, be shielding problems from the company. This is especially the case
where the service provider (ONEIC or OIFC) sees itself as being the primary
customer interface, with responsibility for resolving all customer issues relating to
meter reading, bill distribution and collection. This means that the company fails
to capture, act on and learn from service delivery failures and means that
customers may be given inadequate responses to problems that they report,
causing a potential breach of the complaint handling procedure.
Closure of the complaint. Practices vary between companies in the way that
complaints are closed. In some the practice is to send an SMS to the
complaining customer with a brief explanation (of any adjustment/amendment)
and invite them to call (the call centre or visit a convenient office/branch) if they
require more detail or a letter. In other companies, all complainants receive an
individual telephone call from an agent explaining what the company is
proposing by way of resolution. This is compliant with the requirement of the CHP
that companies should provide a proper explanation to customers and to verify
the customers understanding of the actions taken. There were two other matters
worthy of mention that were less immediately related to the compliance
assessment. First, the overwhelming majority of complaints relate to billing; as
can be seen from Table 5 below numbers of other complaint types were not
significant. Second, there are wide variations in the quality of responses to
customers who complain.
Company Meter reading and
billing complaints
Other
complaints
Total
complaints
Complaints
per 10,000
customers
Company O 65 1 66 7
Company I 339 65 404 20
Company S 176 8 184 5
Company D 1,475 8 1,483 48
Company C 6 2 8 2
Table 5: Customer Complaints by Category First Quarter 2016
Following on from our review at the companies‟ offices, AER staff telephoned a
sample for each company of customers who had made complaints. With the
exception of Company D many of the customers claimed not to have received
acknowledgements of their complaints from the companies. Many of the
customers contacted were not satisfied with the service provided, particularly with
communication from the companies.
5.2.6 New connections (Time taken to connect)
Customers expect that requests for new connections are dealt with promptly and
that connections are made within a reasonable timeframe.
When an application for connection is received the companies assess the
application and categorise it according to the work that has to be done to deliver
it. If the application is for a demand of less than 1MW this assessment should be
achieved within seven days, above 1MW, within 90 days. During this period the
categorisation, an assessment of the work required and feedback to the customer
should be achieved.
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The categories of connection are “simple” and “complex”. Within the category of
“simple”, connections are further sub-divided into those that require no network
extension or reinforcement and those that do.
Those requiring no work other than a simple service cable on an existing network
can be processed immediately and the connection programmed as soon as the
connection fee is paid by the customer.
Simple connections requiring work on the existing network are generally managed
by the extensions department in distribution and involve assessing the network
extension requirements to a further level of detail, arranging a contractor and then
the site time to build the extension. Only when this is complete is the customer
expected to pay his connection fee and from that point it proceeds as a simple
connection requiring just a service cable.
A complex connection is one that requests a capacity of 2.5 MW or greater (may
not be consistent across all companies) or is more than 1.5km from the licensee‟s
existing network. The initial assessment is still carried out within the initial assessment
period then passed back to the customer with a statement of requirements to
arrange and pay for his own network extension6. The customer may then work at his
own pace to complete the connection, then notifies the licensee and the
connection is handled in the same was as a new simple connection with no work
request. Again, the final connection can be programmed as soon as the
connection fee is paid.
Figure 2 below presents the overall connections process in generic form, which is
effectively followed, sometimes with minor variations, by all companies. For
anything other than a simple connection requiring no network extension or
reinforcement there are two stages of processing a connection application that are
within the control of the licensee.
6 The customer may only appoint a DCRP approved contractor to carry out the network extension, to
ensure that it will be built to all relevant standards. This includes making the connection to the licensee‟s
existing network.
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Figure 2: Generic new connections process
As described above the connection process can be involved and relies on
cooperation and effective channels of communication between supply and
distribution departments. Our overall conclusion is that these were generally in
place and connections appeared to be quite well controlled. There is some
evidence of very good practice, though a general statement would be that the
process is too involved, potentially turning a straightforward process into something
more than it needs to be with too many handovers between departments.
However, in the cases we examined the work was well tracked and staff were able
to provide an update on progress. Furthermore, the number of complaints
recorded and VoC outputs indicates reasonable levels of customer satisfaction.
As part of the quarterly AER KPI reporting pack the companies are required to
indicate the average time, in days, taken to make simple new connections and
complex connections. The reports for the quarter ended March 2016 show the
average time to make a simple connection to the network varies between the
companies from one to seven days. In the case of complex connections, Company
C reports an average of 54 days, Company D 4.5 days, Company O less than one
day and Company S and Company I were unable to identify the time taken. These
reported timings have little meaning and do not reflect the customer experience.
This demonstrates that the intention of the KPIs is not well understood and the intent
of monitoring the true customer experience is not being achieved.
Applicatio
n
Company reviews
application to categorise and
respond to
customer <1MW 7 days
>1MW 90 days
Simple
connection,
no network
extension
Simple
connection with
network
extension
Complex
connection
No work
Company
arranges work
and is responsible
for time taken
Customer
arranges work and is
responsible for
time taken
Customer pays connection fee
Connection
made
Monitored but not
currently returned
to AER
Not monitored,
mixed responsibility
for time taken, not
currently returned
to AER
Monitored and
typically returned
to AER as
connection time
in KPI returns
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Customers are interested in the overall time taken from an initial application to the
final connection but the companies, with the exception of Company D, appear to
be reporting the time taken from when the customer pays the final fees to the date
of connection. This is only a small part of the process but is one part that is directly
under the control of the companies for all categories of connection. There are
parts of the overall process that are outside the control of the companies, for
example waiting for customer information or government approvals, or waiting for
the customer to complete their own part of the works.
For this reason, under the current reporting mechanism to AER complex connections
may appear in some cases to be dealt with more quickly than simple connections.
The time reported starts when the connection fee is paid, and the licensee already
has advance knowledge of the application in the case of a complex connection.
We recommend that the KPI reporting mechanism to AER is overhauled to reflect
the customer experience of the actual connection process. Otherwise, the
reported KPIs will have little meaning and possibly misrepresent reality. They will
certainly not be a basis for comparison between licensees.
SR10. The following KPIs related to connections are introduced.
Connections KPI-1 (applicable to all connection types). Time to provide the
customer with a substantive response to his initial application. Standard: % response
within 7 days for applications below 1MW and within 90 days above 1MW7. This is
generally monitored already and should involve no additional recording work by
the licensees.
Connections KPI-2 (applicable to simple connections requiring network extension).
Time to complete the necessary connection works for a connection of below 1MW.
This is generally not measured at present in a regulatory capacity but will be from a
contract management perspective. It is the area most likely to result in poor
customer service and complaints and is currently invisible to a large extent.
Connections KPI-3 (applicable to all connection types). Time to provide the final
connection from receipt of customer payment. It is this final stage that is currently
seen by licensees as the regulatory requirement on which they have to report.. It is,
however, the shortest, easiest to deliver, part of the process that measures only the
time taken after all major issues and delays have been identified and resolved. It is
not representative of the customer experience
5.2.7 Special Needs Customers (Delivery of COP)
All companies have in place a code of practice covering their licence obligations
to have in place arrangements to serve customers who are disabled, chronically
sick, have limited income or are of pensionable age. In supply businesses that are
subject to increasing commercial pressures, this licence condition is a timely
reminder to companies that they retain important utility functions in supporting the
weak and vulnerable in society.
The Codes commit companies to fulfil their licence obligations. Although some are
better presented than others, and the effort given to communicate the codes
varied, the main differences between companies is in the way in which the
commitments in the codes are delivered.8
7 Quite separate from the reporting mechanism we believe that the increase from 7 days to 90 days is
too great for provision of a standard substantive response. We recommend that this should be brought
down to 30 days with a target of 90%, and explanation on individual cases that exceed this. period
8 Thus in one company, the code was not readily available in its branch offices and the telephone
number quoted on the code was not the toll free contact centre number – where SN customers through
which customers were, we were told, encouraged to make contact with the company.
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Two examples will illustrate the extent of the differences. In one company during
the phase 1 visit it was noted that there was no agreed and readily available list of
SN customers. There were examples of the treatment afforded to SN customers
during outages which was entirely appropriate, but access to this support (typically
advance notification of an outage, supply of a mobile generator and
monitoring/keeping in touch during an actual or potential loss of supply) depended
on the local knowledge of staff in the service centres and especially those
operational staff dealing with outages. This was, in our view, a non-compliance with
licence condition 41. Between the first and second visits however, first steps had
been taken to create and then communicate a fully functioning SN register
(contact with the Ministries of Health, Social Affairs as well as a charitable
Committee working on behalf of those with health issues and disabilities; publicity;
and compilation of a detailed register which included all relevant information that
the company‟s staff might require). Though regarded by the company as „work in
progress‟, a framework for complying with the licence condition and code had
therefore been put in place.
In Company O by contrast, the SN register had been thoroughly developed, was up
to date and well communicated both internally to all functions and externally to a
broad range of stakeholders. The company made regular contact with SN
customers to ensure they (the company) had a clear understanding of SNCs‟
requirements – and indeed whether the need still existed. The register was active
and used by others, especially distribution for outage planning and management.
The Code was readily accessible through multiple channels and staff were aware.
An impressive innovation was that the customer‟s meter cabinet was labelled
(discreetly), as were the feeder and substation to indicate the presence of a SNC.
This approach - involving physically signing equipment - provided a fail-safe method
of ensuring that all operatives and contractors were aware that a SN customer
might be affected by a loss of supply.
Other companies had taken useful initiatives including for example Company C‟s
outreach programme and Company D‟s inclusion of some of its SN customers on
GIS which has the potential to improve service provision to SN customers during
planned or emergency outages.
The results of the telephone survey undertaken by AER generally support our
findings. With the exception of Company O, there is a need for all companies to
improve their communication with SN customers and give a high priority to
customers who rely on medical machines.
5.2.8 Outage Management (Customer communications)
Customer communication during planned and unplanned outages is completely
dependent on good internal communication between the customer service
business team and the distribution engineering operations team. Without this
effective internal liaison, communication with customers can never be effective. As
may have been predictable, the licensees vary in their level of communication
during outages. Some are very good and may reasonably be described as close to
international best practice while others still have some way to go.
It would be reasonable to say that Company O, whilst being one of the latest in the
implementation programme for the Blueprint, is already a sector leader on its
customer communication channels. It has implemented its Customer Contact
Centre, which at this stage remains largely distribution focused (most customer
service contact is still via Company Y) and appears to have a robust working
arrangement established between its distribution team, its Network Control Centre
and the customer Contact Centre.
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5.2.9 Quality of Front Line Advice
As part of the phase 2 visits, we reviewed the quality of advice to customers
provided by companies. The process for delivering advice is in transition, as
companies adopt the Blueprint organisation structure on a phased basis. In basic
terms, this means setting up a single customer contact centre9 in each company at
a head office site, accessed via a toll free number (plus in some cases, messaging
applications, social media and email), which is intended to be the focus for most
interaction between the company and its customers. Infrastructure (e.g. AMR) and
technology (e.g. green billing) will reinforce this transition.
For example, there are four fully functioning contact centres and at the time of the
visits, one was in the process of transitioning to become two – one for supply matters
(available from 8 am until 8 pm) and one for distribution (24 hours, every day), with
access via IVR.
A consequence is that the role of service centres or branch offices10 is also in
transition, from being the face of the company for all matters relating to electricity
supplies, towards having an exclusive focus on connections to the network and
distribution matters. Thus companies are encouraging all customers with supply and
customer service type business to route their queries via the Contact Centre – and
staff in service centres were briefed accordingly to direct customers to the Contact
Centre.
Linked to this is the changing relationship between companies and the MRBC
service provider(s), with the Blueprint encouraging the companies to take control of
the customer relationship and manage it directly.
The transition means that there is no current single model. The range is from the
Company O legacy arrangement in which Company Y undertakes the range of
MRBC functions on behalf of the company and provides the main interface with the
customer, through to the situation one location in Company C‟s franchise area
where through a combination of circumstances, the company reads meters
(manually by contractors retained for emergency repairs and maintenance
pending the resolution of AMR problems), delivers bills, accepts cash and other
payments (via a cashier‟s desk at their service centre on the Island) and deals with
queries, for example LPCoP matters via the service centre office on the island.
Though working within the Company C policy framework, the local service centre
offers a relatively self-contained „one stop shop‟.
During the transition, service centres or branch offices continue to play a central
role at the customer interface. The ideal service centre provided an atmosphere
welcoming to customers, had clear signage and queuing arrangements,
appropriate literature available, and was staffed by trained and knowledgeable
staff (especially the front desk agents). These attributes are set out in the table
below.
‘Model’ office Office in need of improvement
Exterior - well signed, visible logo, notice of
office hours, out of office hours toll free
contact number prominently displayed.
Exterior – anonymous exterior to the building,
out of normal hours contact arrangements
not shown.
Interior – clean and spacious. Space and Interior – not laid out as a customer service
9 Business separation means that the contact centre will, at least in larger companies, be split between
those dealing with supply and those dealing with distribution. This is being implemented in MEDC at the
time this report was in preparation.
10 Companies use different titles to describe their locally based offices – service centres and branches
being the most common.
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‘Model’ office Office in need of improvement
seating for customers to wait. Queuing
management system/arrangement.
Literature (e.g. codes); relevant forms (e.g.
connection application); and guidance (e.g.
banner of connections
process/requirements) displayed and/or
available.
reception area, normal office furniture rather
than service „pods‟.
Some literature available but not
comprehensive. Forms available on request.
Little or no use of banners/posters to provide
those waiting with guidance on key customer
service processes.
Confidential area(s) for discussing sensitive
matters.
Lack of confidential areas.
Trained and knowledgeable staff. Use of contractors/temporary staff.
Bill paying facility in or adjacent to the office
(either Company‟s own or ONEIC/OIFC).
No bill paying facilities on site.
Table 6: Service Centre Comparison
Not all offices were visited. However, each company presented an office which
met the criteria of what is generically described as a „model‟; there were others
however, that were less impressive but each company had plans to upgrade and
improve those in need of attention.
All companies had in place induction arrangements for new staff and for on-going
training in customer service skills. Agents, whether in a service centre/branch or in
the Contact Centre were either trained and knowledgeable, or working towards to
being so.
Under direction from the shareholder, Nama, all companies are moving towards a
customer service organisation with the Contact Centre as its focus. Success in
adopting the Blueprint model has not however been the only criterion used for
assessing the quality of frontline advice since at the time of this compliance
assessment, many customers‟ experience of interacting with the company was face
to face, either via a service centre/branch or the service provider. In one company
at least, there was confusion expressed about the long term intention of Nama
regarding the future of the supply business, to the extent that there was the belief
that there could be single customer service centre to cover the whole sector. This
would seem to be contrary to the moves already made to make the companies
autonomous and we believe it to be confusion, rather than fact. None the less, it is
in the minds of some staff and it would be of benefit to all if this situation were
clarified.
5.2.10 Phase 2 Specific Assessment All Company Comparison
Company
O
Company
I
Company
S
Company
D Company
C
Meter reading (Verification of
KPI) 3 3 5 3 3
Meter reading (Verification of
DLP) 1 1 4 2 4
Late Payment COP (Ability to
Pay Guidelines) 1 4 2 3 3
Late Payment COP
(Disconnection notices) 2 2 3 2 2
Complaint Handling
Procedure 2 4 3 4 4
New Connections (Time taken
to connect) 3 3 3 3 3
Special Needs (delivery of 5 2 3 4 3
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Company
O
Company
I
Company
S
Company
D Company
C
COP)
Outage Management
(Customer Communications) 5 3 3 4 4
Quality of Front Line Advice)
5 3 4 5 4
Table 7: Phase 2 Specific Compliance Assessment - All Company Comparison
(A score of 5 is very good, 3 at an adequate level, 1 is poor, 2 and 4 intermediate
levels.)
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6 Overview of licence and code compliance
For each licensee we present the radar plots below.
6.1 Company O
Figure 3: Company O Overview Assessment
Figure 4: Company O Company Specific Code Assessment
Company O scores well in aspects where it is in control of both policy and delivery.
It is the leader in terms of its obligations to Special Needs Customers, its processes for
handling connections applications and communicating with customers during
outages very good, as is front line advice from its own offices. However, it is running
serious risks of breaching regulatory requirements in all aspects where it is reliant
upon Company Y for delivery. With appropriate replacement of its legacy contract
0
1
2
3
4
5
Understandingof RegulatoryFramework
Well definedbusiness
owners for eachRegulatoryObligation
Sufficient RiskManagement on
RegulatoryObligations
Adequate ITsystems for
internalreporting
No conflictinginstructions
SLAs andContracts
0
1
2
3
4
5
Meter readingVerification of
KPI
Meter reading(verfication of
DLP)
Late PaymentCOP (ability to
pay Guidelines)
Late PaymentCOP
(disconnectionnotices)
ComplaintHandling
Procedure
NewConnections
(time taken toconnect)
Special Needs(Delivery of
COP)
OutageManagement
(CustomerCommunicatio…
Quality of FrontLine Advice)
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Company O will be in a good position to address these poor scores through
effective management of the new contract.
6.2 Company I
Figure 5: Company I Overview Assessment
Figure 6: Company I Specific Code Assessment
Company I management has inherited a business that has suffered years of
mismanagement of customer services, for example no disconnections for non-
payment in five years leaving a massive issue with debt management and no
special needs register, until very recently. The current team has also discovered
serious issues with its meter reading contractor and the adequacy of its meter
reading accuracy, which could be attributed to incompetence, or worse. The
current team is making some headway and has demonstrated areas of compliance
that are ahead of others. There is unlikely to be a quick transition to full compliance
0
1
2
3
4
5
Understandingof RegulatoryFramework
Well definedbusiness
owners for eachRegulatory…
Sufficient RiskManagement on
RegulatoryObligations
Adequate ITsystems for
internalreporting
No conflictinginstructions
SLAs andContracts
0
1
2
3
4
5
Meter readingVerification of
KPI
Meter reading(verfication of
DLP)
Late PaymentCOP (ability to
pay Guidelines)
Late PaymentCOP
(disconnectionnotices)
ComplaintHandling
Procedure
NewConnections
(time taken toconnect)
Special Needs(Delivery of
COP)
OutageManagement
(CustomerCommunicatio…
Quality of FrontLine Advice)
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in Company I and the management team will require time and adequate support
to deliver it. New information systems will help.
6.3 Company S
Figure 7: Company S Overview Assessment
Figure 8: Company S Electricity Company Specific Code Assessment
Company S was the first to implement the Blueprint for customer service and the
transformation is progressing well with no major areas for concern, though there is
more to do to bring application of the Late Payment Code of Practice up to the
expected level. Systems are being effectively implemented and, while there are still
issues to address, appear to be working well. Company S has a contract with its
service provider with suitable incentives and penalties.
0
1
2
3
4
5
Understandingof RegulatoryFramework
Well definedbusiness owners
for each…
Sufficient RiskManagement on
Regulatory…
Adequate ITsystems for
internal…
No conflictinginstructions
SLAs andContracts
0
1
2
3
4
5
Meter readingVerification of
KPI
Meter reading(verfication of
DLP)
Late PaymentCOP (ability to
pay Guidelines)
Late PaymentCOP
(disconnectionnotices)
ComplaintHandling
Procedure
NewConnections
(time taken toconnect)
Special Needs(Delivery of
COP)
OutageManagement
(CustomerCommunicatio…
Quality of FrontLine Advice)
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6.4 Company D
Figure 9: Company D Overall Assessment
Figure 10: Company D Specific Code Assessment
Company D is well advanced with implementation of the Blueprint for Customer
Service and is achieving benefits from it, although some aspects of customer service
require significant improvement. There continue to be problems of integration of
different systems and coordination between the different customer service
departments which is adversely affecting customer service. The high score on front
line advice is largely down to progress with its Contact Centre. Aspects of its
relationship with its contractor have resulted in poor customer service, which needs
to be addressed, and there is some hostility in the relationship with the contractor.
Company D manages its business performance with priority on commercial issues
and KPIs and must not lose sight of its regulatory obligations.
012345
Understanding ofRegulatoryFramework
Well definedbusiness owners
for each…
Sufficient RiskManagement on
Regulatory…
Adequate ITsystems for
internal reporting
No conflictinginstructions
SLAs andContracts
0
1
2
3
4
5
Meter readingVerification of
KPI
Meter reading(verfication of
DLP)
Late PaymentCOP (ability to
pay Guidelines)
Late PaymentCOP
(disconnection…
ComplaintHandling
Procedure
New Connections(time taken to
connect)
Special Needs(Delivery of COP)
OutageManagement
(Customer…
Quality of FrontLine Advice)
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6.5 Company C
Figure 11 Company C Overall Assessment
Figure 12: Company C Specific Code Assessment
Company C was one of the early companies in the implementation of the Blueprint
and has benefitted in terms of front line advice through the establishment of a well-
run contact centre, influencing its scores on front line advice, outage management
and complaint handling. It has moved billing house and leads its debt collection
and disconnection from the central billing team. However, the dispersed nature of
the Company C networks and customers means that there is a level of autonomy in
the regions currently beyond the visibility of the centre with insufficient information
systems to be able to track what is actually happening on the ground.
0
1
2
3
4
5
Understanding ofRegulatoryFramework
Well definedbusiness owners
for each…
Sufficient RiskManagement on
Regulatory…
Adequate ITsystems for
internal reporting
No conflictinginstructions
SLAs andContracts
0
1
2
3
4
5
Meter readingVerification of KPI
Meter reading(verfication of
DLP)
Late Payment COP(ability to pay
Guidelines)
Late Payment COP(disconnection
notices)
ComplaintHandling
Procedure
New Connections(time taken to
connect)
Special Needs(Delivery of COP)
OutageManagement
(CustomerCommunications)
Quality of FrontLine Advice)
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7 Appendix 1: Phase 1 Overview Questions Template
Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
A Organisation And Accountability
A1 Please describe your organisational structure and facilities for delivery of all aspects of customer service
Management reporting lines?
Customer Access Channels?
Call centre(s)?
Zonal Offices?
Toll free phone numbers?
Web site?
SMS messaging?
Social media?
Others?
A2 How does your structure map across to your licence obligations, and are accountabilities and processes clearly defined for:
A2a Customer Complaint Handling Procedure?
A2b Supply Terms?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
A2c Late Payment COP?
A2d Special Needs COP?
A2e Efficient Use of Electricity COP?
A2f Connections and Relocation?
A2g Other, please describe?
A3 What are the reporting lines and who are the designated accountable managers for:
A3a Customer Complaint Handling Procedure?
A3b Supply Terms?
A3c Late Payment COP?
A3d Special Needs COP?
A3e Efficient Use of Electricity COP?
A3f Connections and Relocation?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
A3g Other, please describe?
A4 How is information gathered and verified to prepare the regulatory KPI returns?
A5 Is any additional management information beyond regulatory KPIs gathered as management information?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
B Blueprint for Customer Services
B1 What is your view of the appropriateness of the Blueprint?
B2 Is the company going to adopt the Blueprint completely or in part?
B3 What stage of delivery of Blueprint is the company now at?
B4 Is the company implementing any items additional to the Blueprint?
B5 Is there an action plan for implementation of the Blueprint?
B6 If not, is there a reason, and how is implementation being managed?
B7 What is the time frame for implementation of the action plan (if applicable)?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
C Meter Reading, Billing And Collection
C1 Please describe the current meter reading and billing process
C2 Please describe current arrangements for:
C2a Meter Reading?
C2b Billing?
C2c Account collection?
C2d Account queries?
And if outsourced:
C3 How are they managed?
C4 What contracts are in place?
C5 How do you know the company is receiving good value?
C6 How do you judge the contractors’ performance?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
C7 How are they performing, are there any specific problems?
C8 Are there specific performance indicators on these contracts?
SLAs?
KPIs?
C9 How are these arrangements expected to change over the next two years?
C10 What is your perception of how contractors represent your company to customers?
C11 What management information is gathered on contract performance?
C12 What KPIs exist on the contract SLAs, how prepared, implemented, returned?
C13 How do these feed into internal management KPIs?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
C14 What redress or penalty provision does the company have in the case of contractor default?
Customer Records and Accounting
C15 What controls are in place to ensure all customers are on record?
C16 What controls are in place to ensure all meters are read?
C17 What controls are in place to ensure all customers are billed every month?
C18 What controls are in place to ensure all customers pay every month?
C19 What is the process for estimating consumption in estimated readings?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
C20 How do you control and manage repeat estimated readings?
C21 Are exception reports produced to identify any bills that are clearly inaccurate (zero or way above expectations)?
C22 What is the process for making adjustments to bills?
C23 How is this recorded and communicated with the customer?
C24 Who is empowered to make adjustments and what guidelines do they have available?
C25 What is the process for checking meter accuracy in case of dispute?
C26 What feedback do customers receive following a check meter installation or a meter test is carried out?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
D Complaint Handling (CCHP)
D1 How are complaints / queries handled?
D2 What communication channels are available for receiving, providing progress reports and responding to complaints?
D3 How are they recorded and logged?
D4 How is the CRM used in this process?
D5 When does the clock start on complaints?
D6 What are the main categories of complaints received?
D7 What are the main categories of queries received?
D8 How many staff on these activities?
D9 Is it enough to provide expected levels of service?
D10 How do you ensure they have the right levels of skills and experience?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
D11 What specific customer service training have they received?
D12 What authority do front-line staff have to resolve queries?
D13 How do you ensure they have access to key information to resolve queries?
D14 What processes are in place to identify root causes, ensure learning points are identified and prevent recurrence?
D15 How do you ensure that previous regulatory determinations are taken into account?
D16 What process in place to ensure customers are satisfied with the handling of their complaint / query?
D17 How could the Code of Practice be improved?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
E Special Needs COP
E1 May we see you Special Needs Customers Register?
E2 What is the process for updating the register –additions and removals?
E3 How are customers in the Special Needs Register categorised?
E4 How is the Special Needs Register made available to front line staff?
E5 How are staff made aware of COP requirements?
E6 How are customers made aware of COP requirements?
E7 What internal guidelines, manuals and instruction exist?
E8 What is the process for keeping instructions updated and staff aligned with regulatory requirements?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
E9 What provisions, with timelines, do you make for special needs customers?
Payments
During planned / unplanned supply interruptions
Meter positions
E10 How are staff made aware of the special needs provisions?
E11 What liaison is there with distribution departments, to ensure network diagrams marked, and staff know locations of Special Needs Customers?
E12 What proactive steps are taken to contact Special Needs Customers during supply outages?
E13 What arrangements, if any, have been made with other agencies who may be able to support customers with special needs?
E14 How could the Code of Practice be improved?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
F Late Payment COP (LPCOP)
F1 How are staff made aware of COP requirements?
F2 How are customers made aware of COP requirements?
F3 What internal guidelines, manuals and instruction exist?
F4 What is the process for keeping instructions updated and staff aligned with regulatory requirements?
F5 Under what circumstances do you agree payment plans with customers?
F6 What terms do you apply to payment plans?
F7 To what extent are front line staff empowered to agree payments plans?
F8 What Guidelines are available to support staff with payment plans?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
F9 To what extent are prepayment meters used (or could be used) where customers may have difficulty in managing their payments?
F10 When, and by whom is the decision to disconnect a customer for non-payment taken, and is it applied equally to all customers?
Reminder notices
Final Notices
Disconnection Notices
F11 What are the numbers of customers who:
agree payment plans
agree payment plans and default
are disconnected for non payment
remain disconnected more than 24 hours?
F12 How could the Code of Practice be improved?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
G New Connections And Relocation Of Plant
G1 Is there a central point for managing new connections?
G2 Who determines whether a connection is Simple or Complex, and how is it done?
G3 When does the clock start for determining the period a customer has been waiting?
G4 How are customers kept informed during any delay period, if the delay is outside the company’s control? Is there a written process?
G5 What performance statistics are gathered for a) providing a fixed price quote and b) for making the connection?
G6 What percentage of connections are made a) within the prescribed period, b) outside the prescribed period due to external delays, c) outside the prescribed period due to delays in the company?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
G7 What is the process for dealing with requests for relocation of electricity distribution assets?
G8 Are charges made to the customer for relocating assets and if so under what circumstances?
G9 What is the extent of charges that are made, is it the immediate costs of movement or does it include any upstream impact of the movement?
G10 What are the timelines for relocating assets?
G11 How is progress with a request for relocation recorded and communicated with the customer?
G12 What guidelines are issued to staff on relocation?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
H Efficient Use of Electricity COP
H1 How do you help customers with the efficient use of electricity?
H2 How are staff made aware of COP requirements?
H3 How are customers made aware of COP requirements?
H4 What internal guidelines, manuals and instruction exist?
H5 What is the process for keeping instructions updated and staff aligned with regulatory requirements?
H6 What advice do front line staff give customers when contacted?
H7 What resources are available to font line staff to assist with this?
H8 Are specialist advisors available to give on-site advice?
H9 How is energy efficiency advice given recorded?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
H10 Are there any instances where the impact of energy efficiency advice given has been measurable?
H11 What arrangements, if any, have been made with other agencies who may be able to support customers with efficient use of electricity?
H12 How could the Code of Practice be improved?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
I Trouble Call Handling
I1 How does this take account of Special Needs COP?
I2 What information is made available to customers on cause of interruption, likely restoration time, special needs advice during interruption?
I3 What communication channels are used during interruptions for gathering incoming information from customers, and for passing out information to minimise incoming call numbers? What specific contact arrangements for trouble calls are made for special needs customers?
I4 How would you respond to a report of an electrical incident in the home?
I5 What progress has been made on an outage management improvement plan?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
J Key Performance indicators
J1 What management information is gathered on provision of customer services?
J2 Does this go beyond the AER reporting requirements?
J3 How is the information compiled to provide the AER reports?
J4 Is this information independently verified by Senior Management or Auditors?
J5 How is this information used to manage the business / improve performance?
J6 Is there any identifiable improvement or deterioration in reported performance?
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Customer Service Audit Workbook
Question Comments / Notes Evidence provided?
K Risk Management
K1 Please describe how risks regarding regulatory obligations are recognised and escalated to appropriate levels?
K2 How would front line staff recognise these risks?
K3 Where do you see the biggest regulatory compliance risks?
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8 Appendix 2: Phase 1 Overview Assessment Criteria
Each of the assessment areas are shown in column 1.
In column 2 examples of contra (or negative) indicators are provided. Where these are evident, Licensees will not be rated highly. In the
summary table, companies assessed at this level are shown as red. In column 3, are examples of a licensee moving forward but not yet
achieving the requirements of column 4 ranking. In the summary table, companies assessed at this level are shown as amber. Examples of
positive indicators of performance are given (column 4). Where Licensees demonstrate these, they have been rated highly. In the summary
table, companies assessed at this level are shown as green. (In a few exceptional cases a transition between levels has been allowed for.)
Compliance
Assessment Category
(1)
Evidence/contra indicators of weak
compliance (2)
(3)
Evidence/positive indicators of good
compliance (4)
1 Regulatory
framework is
sufficiently well
understood …
Codes appear to be stand alone
documents, not always readily
accessible (e.g. limited channels –
not immediately available to
customers in Branch officers or
Customer Service centres, not easy
to find on the company website).
Codes do not always reflect current
practice e.g. may not refer to the
contact centre toll free number as
the first port of call for customers.
Staff in customer services
interacting with customers do not
refer to Codes in their day to day
work; do not appear to see them as
relevant to the discharge of their
duties.
Codes are compliant, up to date, and
generally available through several
channels – not only the website and
customer service centres.
Staff knowledge is uncertain on some
matters, or they have expertise
confined to their specialist area of
work. Training or briefing may have
been generic, rather than applied to
front line staffs‟ daily interaction with
customers on matters governed by the
Code.
Guidance is documented but not
comprehensive and may not up to
date in all respects; evidence suggests
they (guidance and manuals) were
prepared prior to implementing a
change and thereafter not treated as
„live‟ documents.
Outputs from the Codes may, as a
consequence, be uncertain (e.g. an
Policy and practice informed by the
Licence and Code. Codes are
compliant, up to date, available through
multiple channels, attractively
presented. (e.g. easy to understand,
cross referred to other customer
information, embedded in processes
such as Contact Centre/Branch office
protocol e.g. set out in an up to date
and accurate CS Manual or equivalent).
Staff demonstrate an awareness of the
Codes; how they impact on their day to
day work; and are able to explain their
meaning and application to customers
(e.g. how to deal with special needs
customers, inclusion on the SN register
and maintenance action over time for
this customer group).
Arrangements in place to update on
any Code revisions or key determinations
and disseminate the changes.
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Compliance
Assessment Category
(1)
Evidence/contra indicators of weak
compliance (2)
(3)
Evidence/positive indicators of good
compliance (4)
incomplete SN register that is not
readily accessible to all potential users,
reliance on specialist local knowledge
to support these customers.)
Understanding of the likely direction of
future changes to the framework;
perspective on what they would wish to
see revised and why.
2 Clear business
owners in relation to
the regulatory
obligations …
Organisation does not clearly
identify business owners; may be
partly in place/in transition. Lack of
certainty about a timetable and
evidence of some resistance to the
future direction of change.
Some functions (e.g. CS contact
centre) or posts (e.g. complaints
coordinator) not fully operational,
not filled or shared), with little
evidence of when the matters
would be resolved. New resources
allocated to existing functions
(where volumes would decline)
rather than new functions to be
created.
Little evidence of changes to the
role of HO/contact centre and
local branches/zones to reflect the
Blue Print. e.g. contact centre
focussed on distribution outages,
documentation not available/ out
of date/ does not reflect Blue Print
structures and processes.
SLAs either not in place, under
development or under
renegotiation (e.g. between CS
and Distribution) with unresolved
Organisation which identifies clear
business owners partly in place/in
transition (e.g. toll free contact centre
number not well published); some
„foundation‟ posts unfilled or covered
on an acting basis). Plans in place
which set out what is necessary to
deliver change (e.g. moving towards
Blueprint).
Some functions (e.g.
commercial/supply contact centre) or
posts (e.g. complaints coordinator) not
fully operational, unfilled or
responsibilities shared.
Evidence of changes to the role of
HO/contact centre and local
branches/zones to reflect the Blue
Print. Contact centre fully functional
but focussed on distribution (e.g.
outage management and restoration);
process documentation not available/
out of date/ does not reflect Blue Print
structures/processes for customer
services. Limited evidence of „firm‟
planning for later business separation.
SLAs either not in place, under
development or under renegotiation
(e.g. between CS and Distribution).
Clear business owners (for example as in
the Blue Print organisation structure) are
in place, with the key posts filled on a
permanent basis. Decisions informed by
the future direction of change (e.g.
business separation).
More generally, customer service
functions adequately resourced, both
front line and access to support (e.g.
expertise, time for training, planned
flexibility to cope with peaks of
work/support during outages).
Where there are variations from the
structure, this is explained and owners
(both in terms of the restructured Blue
Print functions and Regulatory
framework) are identified.
Clear and well understood „boundaries‟
of responsibility between (a) Company
and service provider; (b) Head
Office/Contact Centre and
Branch/Zone local office; and (c)
Customer Service and Distribution. SLAs
in place.
Policies and procedure documents (for
example a customer services manual or
an equivalent set of policy documents)
which explain/reinforce this ownership
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Compliance
Assessment Category
(1)
Evidence/contra indicators of weak
compliance (2)
(3)
Evidence/positive indicators of good
compliance (4)
issues and/or lack of specificity on
responsibilities.
Where some policies and procedure
documents (for example a customer
services manual or equivalent) are in
place they are either incomplete
and/or out of date.
are in place.
3 Risk management
processes in relation to
the regulatory
obligations …
Working with the existing MI from
the service provider;
checks/inspections prompted by
exceptions, no evidence of
structured audit having been
conducted.
A senior management issue by
exception, focussed on specific
issues, projects etc. The focus is on
managing within existing structures
and frameworks, using a standard
suite of KPIs.
No evidence of risk being recorded
or escalated. Left to individual
managers to identify, manage and
close out risks.
Working with the existing MI (partly
from the service provider), supported
by occasional verification by the
company; typically checks/inspections
prompted by exceptions.
Senior management issue, typically a
feature of management meeting
agendas; appropriate range of KPIs.
The focus is on managing to improve
operational efficiency and delivering
what is necessary to implement Blue
print and the range of
projects/initiatives planned by the
Shareholder.
Some evidence of risks but not
consistently recorded; issues managed
informally and not always closed out.
Corporate information therefore
partial.
Routine check of MI to ensure accuracy
of regulatory reporting.
Scheduled audit of critical data.
Regulatory reporting and compliance
included on the senior management
agenda and reflected in KPIs; clear
perspective on regulatory risks. (See also
4 below).
Modelling of possible regulatory
incentives/penalties to ensure
understanding of the impact future
scenarios (e.g. process and cost impact
of possible developments next PCR).
Robust contract and operational
management of service provider, with a
clear perspective on what the future
relationship should be. Contingency
arrangements in the event of
contractual/service failure.
Recording of risk, with escalation
processes to appropriate levels of
authority and evidence that issues are
closed out.
4 Reporting systems in
place to enable
Limited MI dashboard which
appears driven as much by what
Well developed MI dashboard shaped
by the regulatory framework. Routine
Comprehensive MI dashboard, which
includes focussed and relevant
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Compliance
Assessment Category
(1)
Evidence/contra indicators of weak
compliance (2)
(3)
Evidence/positive indicators of good
compliance (4)
monitoring by senior
management …
data is available as what is
required. Projects managed
individually and reviewed on an
individual basis. Limited strategic
integration below senior
management level.
Characterised by infrequent
reporting (e.g. quarterly or bi-
monthly rather than monthly).
Reliance on manually compiled
and interpreted data and
reporting, or manual intervention
and presentation of MI. (See above
also 3 above – a standard suite of
KPIs are set).
Regulatory reports and KPI
submissions assembled, collated
and dispatched to AER; occasional
gaps in data; little evidence of
quality checks; rarely
accompanied by any qualifying
commentary.
agenda item for senior managers
which captures regulatory,
Shareholder KPIs and progress on major
CS projects/initiatives.
Systems capture and enable reports
that are accurate and up to date. The
way in which they are complied is
transparent and auditable.
Regulatory reporting and return of KPIs
are accurate and represent
performance; developed using
defined count points and consistently
applied definitions. Few gaps in data.
information – e.g. owner, KPI and
performance against target, critical
issues. Important agenda item on senior
management agenda.
In addition to KPIs, includes reporting on
key CS projects; notes any qualifications
as to data quality, identifies key risks.
More generally, systems capture and
enable reports that are accurate and
up to date e.g. root cause analysis of
complaints (as via the Contact Centre
system); progress on new connections
(CRM). Evidence that these are used to
inform management decision making
and risk assessments. (Also likely to be
important to the setting of future
regulatory performance targets).
Regulatory reporting and return of KPIs are
accurate and a fair representation of
performance, developed using well
defined count points and consistently
applied definitions.
5 No policies or
guidelines which
contradict regulatory
obligations …
Company allows the service
provider to be responsible for
resolving queries and complaints,
sometimes with and sometimes
without the involvement of the
company.
Variation in the discretion exercised
between Branches/Zones. The
extent to which this variation in
practice occurs is sometimes not
No evidence of policies or written
guidelines which explicitly contravene
the Licence obligations or principal
Codes revealed; some gaps in
supporting guidelines/manuals about
how the intent of the Codes should be
delivered.
Evidence of good staff knowledge of
the Codes and their application;
training conducted but appears ad
No evidence of policies or written
guidelines which explicitly contravene
the Licence obligations or principal
Codes revealed.
In the best Companies there is clarity
e.g. certainty that all complaints
registered at the Contact Centre;
consistency of reporting; all payment
plans agreed and are processed
through the Contact Centre in
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Compliance
Assessment Category
(1)
Evidence/contra indicators of weak
compliance (2)
(3)
Evidence/positive indicators of good
compliance (4)
revealed or well documented.
Reliance on the experience and
acquired knowledge of individual
staff for the operation of core
processes (during what is a time of
rapid, multiple changes to
procedures and systems).
hoc and sometimes generic (as distinct
from being focussed on the relevant
work processes).
accordance with clear written
guidelines linked to „ability to pay‟ (with
these being up to date and readily
available in a CS manual or equivalent);
escalation processes in place; staff
trained on the application of these
guidelines and familiar with them; clarity
on the application of each licence
condition and Code.
6 Contracts and SLAs
which … enable
Companies to meet
their regulatory
obligations …
Reliance on the service provider
accepted as the basis for MRBC –
and tacit acceptance that the
service provider will continue.
Service provider retains important
areas of discretion in dealing with
MRBC. Acts as the primary interface
with the customer.
Reliance on senior level meetings
between the company for control;
limited detailed operational
intervention. Checks and
investigations of service provider
driven by the need to address
exceptions, complaints, obvious
errors only; absence of a structured
audit programme of
data/reporting.
Contract renewal based on the
existing basic framework; does not
appear to anticipate future
demands.
Internally, either no SLA between
Well developed plans in place for the
future management of MRBC.
Firm management of the service
provider by routine meetings at an
operational level, reinforced by senior
level interaction. Audit of data and
reporting typically by exception,
response to complaints, obvious errors
etc. Company takes ownership of the
important aspects of the customer
interface.
New/replacement contract under
development. Limited detail available
(indicative of uncertainty about the
possible outcome of negotiations,
scope for competition, in sourcing).
Internally, a draft or signed SLA
between Customer Services and
Distribution, plans, but with limited
evidence of implementation/impact.
Evidence that what the Blue Print
describes as the „exit strategy‟ from
certain service provider arrangements is
thoroughly mapped out and being
progressed against a clear strategic
framework. Evidence of management
ownership across the company.
Firm operational, day to day, control of
the meter reading, bill printing and bill
distribution, and cash collection
processes operated by the service
provider. Extensive efforts at branding all
customer interaction as the company‟s.
Planned - and executed - audit of
service provider activities e.g. meter
reading accuracy, comprehensiveness
(likely to be important to the setting of
future regulatory performance targets as
well as customer satisfaction). Routine
use of own staff to audit.
Well structured and documented
approach to a new/replacement
contract (e.g. which reflects a
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Compliance
Assessment Category
(1)
Evidence/contra indicators of weak
compliance (2)
(3)
Evidence/positive indicators of good
compliance (4)
Customer Services and Distribution,
or one that is draft only, may not be
sufficiently comprehensive, with
elements that may not be future
proof etc.
competitive model, some „in sourcing‟ of
certain functions as in the Blue Print and
carefully designed incentives/penalties).
Contract terms reflect clearly regulatory
obligations and include sufficient
flexibility to enable future developments.
Internally, a clear and well understood
SLA between Customer Services and
Distribution (signed, and actively
managed).
Table 8: Phase 1 Assessment Criteria
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9 Appendix 3: Phase 2 Code Specific Assessment Criteria
Assessment criteria – Detailed Licence and Code Compliance – General description and actions
Assessed level of
compliance 1 2 3 4 5
General
descriptor
Non compliance. Code
published (each
company has done this)
but little or no evidence
that it is operational.
Improvement essential.
Evidence of actual/
potential breaches of the
Code. Scope for
significant improvement.
Evidence of essential
compliance, with the
possibility of minor
breaches. Scope for
improvement in some
areas.
Evidence suggests the
company‟s policy and
practices are compliant
in all important respects.
Scope for minor
improvement (e.g. as
part of an overall CS
plan).
Evidence that the
company‟s policy and
practices are compliant
with the Code.
Improvements required
are minor and
operational. Examples of
innovation and/or good
practice are evident.
Expected actions Requires urgent remedial
actions, to be specified
by AER and delivered to
a timetable specified by
AER.
Requires actions to be
submitted by the Disco
to AER and agreed by
AER within 3 months,
Actions to be delivered
to an agreed timetable.
Requires an
improvement plan to be
submitted by Disco to
AER within 3 months,
which includes an action
plan and where
appropriate, timetable.
Report to AER on
completion, timing to be
set at the discretion of
the company.
Requires a report on
progress on addressing
the issue by the
company to AER within 6
months.
Routine monitoring/
reporting in other
respects.
Routine reporting only;
monitor by exception
only.
Table 8: Phase 2 General Assessment Criteria
Meter reading data verification (and KPIs)
Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to
verification and
audit of data
Data not reported to
AER.
Verification tends to be
Data reported to AER
uncertain (Indication
that reports are
incomplete, or
Data reported to AER
uncertain (Indication
that reports are
generally complete but
Report completed and
submitted.
Routine data
verification, to an
Full understanding of
AER‟s requirement – and
compliance with it when
reporting KPI.
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Assessed level of
compliance 1 2 3 4 5
submitted to AER
via KPI returns.
ad hoc.
Reliance on the service
provider who manages
the data, conducts any
checks they consider
appropriate in
accordance with their
own systems, and
presents reports to the
licensee. Evidence
suggests that these
reports are typically
accepted at face
value.
inaccurate).
Occasional verification
in response to specific
problems which
become „visible‟ to
senior managers/AER
and therefore require
action.
Reliance on the service
provider who manages
the data, conducts any
checks in accordance
with their own systems,
and presents reports to
the licensee. No
evidence of routine
audit.
concerns about
accuracy).
Occasional verification
in response to specific
problems.
Reliance on the service
provider who manages
the data, conducts any
checks in accordance
with their own systems,
presents reports to the
licensee, responds to
enquiries. Evidence of
occasional audit.
SLA/contractual
arrangement either
silent or rarely referred to
on verification and/or
audit matters.
agreed
programme/timetable.
Service provider
manages the data but
in a manner prescribed
by the licensee, working
to a clear
SLA/contractual
arrangement. This
includes standards of
transparency; there is
evidence of audit.
Systems used to gather
data are effective and
transparent. Verification
is routine. Evidence of
data accuracy
problems being resolved
where identified.
Where there is reliance
on a third party/service
provider, the
SLA/contractual
arrangement is
comprehensive,
targeted (with penalties
and incentives relating
to accuracy as well as
performance) with
evidence that data is
regularly verified and
subject to routine audit.
Table 9: Meter Reading KPI Assessment Criteria
Meter reading DLP problems (and KPIs)
Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to
verification and
audit of data
submitted to AER
via KPI returns.
DLP devolved to the
service provider.
Reliance on the service
provider to deliver the
service; reports (often
incomplete or of
uncertain accuracy)
supplied by the service
provider appear to be
accepted at face
Evidence which
suggests the data on
DLP is not reliable. Not
routinely verified.
Some examples of DLP
cases which have
existed for a long period,
with ad hoc efforts (e.g.
in response to
complaints) to resolve
Data on DLP reported
and occasionally
verified.
Some examples of DLP
cases which have been
outstanding for some
time. Appreciation of
the problem, with cases
being resolved as
Data on DLP reported
and occasionally
verified. Ad hoc - or
planned for the future -
audit of data.
Clear contractual
relationship; some
uncertainty about the
extent to which the
service provider is
Documented and well
understood process - by
companies‟ own staff
and those of the service
provider - to identify and
control DLP. Clear
procedure with
escalation arrangement.
Root cause(s) of DLP
investigated, followed
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Assessed level of
compliance 1 2 3 4 5
value.
Many examples of DLP
cases which have
existed – in some cases
for years – with little
effort to resolve them.
Limited if any AER
reporting.
them.
Reporting to AER based
on service provider
data, not routinely
verified.
resources permit.
Reporting to AER using
service provider data,
verified from time to
time.
delivering.
Some examples of DLP
cases which have
existed for some time.
However, the licensee
has a plan/timetable to
address the problem.
Evidence suggests
reporting to AER is
generally reliable.
and resolved;
reliable/verifiable data
on any outstanding for a
(defined) period.
Progress monitored/
reported to
management.
SLA/contractual
arrangement is clear
and comprehensive on
what is required of the
service provider.
Information provided to
AER is comprehensive
and reliable. There is a
full understanding of
AER‟s requirement and
compliance with it when
reporting.
Table 10: Meter Reading DLP Assessment Criteria
Late Payment Code of Practice
Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to the LP
CoP. (All
companies have
a Code).
Licence condition
41 „ setting out
the methods for
dealing with
Customers who
CoP in place which
includes basic content
only. Available on the
website, in some but not
all offices/branches, or
on request.
Shared responsibility with
the service provider who
also agrees instalment
payment plans in some
CoP in place which
covers the essential
points. Available on the
website and generally at
offices/branches.
Shared responsibility with
the service provider who
also agrees instalment
payment plans within
agreed parameters.
Code of practice in
place which covers the
essential points. Reflects
actual practice in most
important respects.
Copies generally
available through
several channels.
Company/service
provider responsibilities
Clear, well written CoP,
which reflects actual
practice in the
company in all
important respects.
Copies readily available
externally through
multiple channels.
Company/service
provider responsibilities
Clear, well written CoP,
which reflects actual
practice in the
company in all details.
Copies readily available
and positively promoted
externally through
multiple channels.
Included in campaigns
and outreach activities.
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Assessed level of
compliance 1 2 3 4 5
incur obligations
to pay for
electricity
supplied by the
Licensee and who
have difficulty in
discharging those
obligations…‟
circumstances;
characterised by a lack
of clarity over „who does
what‟.
Lack of clear
procedures or guidance
on the basis on which
payment plans are
agreed; no
consideration of ability
to pay. This leads to
inconsistency (and
possibly discrimination)
in managing late
payment matters.
No evidence of active
debt management to
prevent the
accumulation of debt in
the first place.
Disconnections not
managed or recorded
consistently – nor are
reconnections.
Disconnection notices
not delivered.
Data on disconnections
– and hence the
information on which
KPIs are reported –
inconsistent, uncertain
Guidance on payment
plans – but incomplete
(e.g. no reference to
ability to pay).
Little evidence of active
debt management to
prevent the
accumulation of debt in
the first place.
Disconnections and
reconnections not
managed consistently
(e.g. disconnection
notices not always
delivered).
Inconsistent reporting;
concerns over gaps and
errors; KPIs unreliable.
generally well known
and understood.
Guidance on payment
plans; whether or not
ability to pay is taken
into account depends
on the knowledge and
skill of staff member
dealing with the case.
Some evidence of
active debt
management to
prevent the
accumulation of debt in
the first place.
Disconnections and
reconnections not
managed consistently
(e.g. some evidence
that disconnection
notices may not always
delivered).
Evidence of some
inconsistencies in
reporting; KPI reporting
may not capture all
data.
known and understood
by all staff involved.
Guidnace on ability to
pay is reflected in
decisions on paymenyt
plans.
Evidence of active debt
management to
prevent the
accumulation of debt in
the first place.
Disconnections and
reconnections
managed consistently
(e.g. individual
examples of
disconnection notices
not always being
delivered).
Reporting is generally
accurate and reliable,
shared between
company and service
provider; reporting to
AER generally good.
Clearly set out
responsibilities for those
managing and
implementing the Code,
covering the company
(e.g. between CC,
Collection and Billing)
and the company and
third parties (e.g.
between the company
and service provider).
Staff well trained and
familiar with the
processes and ability to
pay matters.
Pro active debt
management,
consistently applied.
Clearly understood and
consistently applied
procedure for
disconnection (e.g.
issuing of disconnection
notices in all cases).
Comprehensive data
set, used by service
provider and staff.
Accurate reporting to
AER.
Table 11: Late Payment Code of Practice Assessment Criteria
Complaints Code of Practice
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Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to the
Complaints CoP.
(All companies
have a Code).
Licence condition
24 „ requires
electricity
Suppliers to
effectively and
transparently
resolve customer
complaints in a
timely manner „
CoP in place which
includes basic content
only. Available on the
website, in some but not
all offices/branches, or
on request.
Service provider sees
their role as solving
complaints associated
with their functions – and
may not report all to the
company.
Individual staff dealing
with customers
determine what
constitutes a complaint.
As a consequence
regulatory reporting may
contain inconsistencies.
May also be incomplete
(for example, service
provider generated
complaints may not be
captured).
Staff guidelines, where
they exist, out of date
and/or too basic to
ensure a consistent
procedure is followed.
Training is characterised
as being ad hoc.
KPI reports are created
and submitted to senior
management and AER.
Little evidence that
these are subject to
CoP in place which
covers the essential
points. Available on the
website and generally at
offices/branches.
Individual staff dealing
with customers
determine what
constitutes a complaint,
though on the basis of
management briefing
and on job training.
Some differences
between locations. As a
consequence reporting
may contain
inconsistencies.
Staff guidelines, where
they exist, maybe out of
date and thereby not
ensure a consistent
procedure is followed.
Training is planned and
delivered but may be
characterised as mainly
generic rather than
being process specific.
Complaints are closed
by SMS, with more detail
offered if the customer
calls again, goes to a
customer service
centre/branch.
KPI reports are created
and submitted to senior
management and AER.
Some evidence that
Code of practice in
place which covers the
essential points. Reflects
actual practice in most
important respects.
Copies generally
available through
several channels.
Definition of what
constitutes a complaint
covered by general
guidance. Some scope
for differing
interpretations as a
consequence, which
may affect the customer
experience and the
reliability of regulatory
reporting.
High profile complaints
may trigger changes
following an
investigation and
implementation of
lessons learned.
Basic process is
described in guidelines
for CC (and branch
level staff); focussed
training given to those
handling complaints as
required. Complaints are
closed by SMS, call back
or email.
Reporting is generally
good; some manual
intervention (thereby
Clear, well written CoP,
which reflects actual
practice in the
company in all
important respects.
Copies readily available
externally through
multiple channels.
Consistently applied
definition of what a
complaint is.
Complaints are
recorded and tracked
using a transparent
system. Confident that al
complaints are
recorded and tracked.
Role of the service
provider in complaint
handling clear; little
evidence of the service
provider
concealing/masking
complaints
Process is described in
guidelines which support
the Code. Quality
checks by exception, -
which then lead to
lessons being
learned.100% of
complaints are closed a
call back or
personalised email.
Staff handling
complaints well trained.
Clear, well written CoP,
which reflects actual
practice in the
company in all details.
Copies readily available
and positively promoted
externally through
multiple channels.
Included in campaigns
and outreach activities.
Well understood and
thoroughly applied
definition of what a
complaint is.
All complaints, from
whatever source (e.g.
including those relating
to the service provider,
as well as all internal
Departments/functions.)
are recorded and
tracked.
Process is described with
precision and included
in a broader manual or
policy document.
Includes appropriate
quality checks and
mechanism for learning
lessons – which are
applied in practice.
Staff handling
complaints well trained
and good level of
awareness more
generally among staff.
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Assessed level of
compliance 1 2 3 4 5
quality checks.
Senior management
action on the report
limited.
these are subject to
quality checks. Senior
management action on
the report appears
limited.
creating scope for
errors).
Performance reported
regularly. Occasional
analysis and reporting of
trends.
Evidence of at least one
example of senior
management action
arising from
consideration of
complaints reporting
during last 3 months.
Transparent reporting,
using KPIs; some
indicators defined in
general terms only.
Reports are sometimes
accompanied by
explanatory narrative
based on diagnostics,
trends etc. Evidence
that performance is
considered/acted on
regularly by senior
management.
Transparent and
auditable reporting,
using appropriate
definitions of KPIs,
accompanied by
narrative and
diagnostic/ trends
analysis. Evidence that
performance is
considered/acted on
regularly by senior
management.
Table 12: Complaint Handling Code of Practice - Assessment Criteria
Network Connections
Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to
connecting
customers to the
network. See
commentary in
the report for
more detail.
Statement of what is
required of customers
wishing to connect not
easy to interpret,
typically requires staff
intervention for
customers to be able to
understand/complete.
Customers have to visit
the office and see a
member of staff to have
the process explained.
Statement of what is
required of customers
wishing to connect
including statement of
charges.
Customers have to visit
the office, limited
documents available to
pick up, most need to
see a member of staff to
have the process
explained.
Statement of what is
required of customers
wishing to connect (all
evidence and
approvals) including
statement of charges.
Some documentation is
available and some
explanatory
posters/banners in
place. Staff available to
help explain the process.
Statement of what is
required of customers
wishing to connect (all
evidence and
approvals) including
statement of charges.
All documentation
available and on
display; forms available.
Staff ready to help
explain the process.
Systems enable
Clear statement of what
is required of customers
wishing to connect (all
evidence and
approvals) including
statement of charges.
Process is well
communicated (e.g.
process chart, list of
authorities/documents
required, application
form) readily available
and easy to use.
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Assessed level of
compliance 1 2 3 4 5
Systems limited (e.g.
reliance on ad hoc
spreadsheets). KPI
reporting to AER does
not occur (e.g. returns
left blank).
Evidence of complaints,
which appear to have
reoccurring „source‟
problems.
Systems limited (e.g.
reliance on ad hoc
spreadsheets). KPI
reporting to AER occurs
but is uncertain – no
attempts to obtain
clarity over what is
required.
Evidence of complaints,
some of which appear
to have reoccurring
„source‟ problems.
CRM used to track
progress of simple new
connections, plant
relocation etc; other
systems(s) for complex;
typically these systems
are not integrated. KPI
reporting tends to be
what can be captured
rather than what is
required.
Evidence that
complaints tend to be
resolved satisfactorily
and in a timely manner.
connections/relocations
of plant etc to be
tracked and reported
on. KPI returns accurate
– but not always helpful
in reflecting the
customer experience or
what AER actually
requires.
Complaints are few in
number and tend to be
resolved satisfactorily
and in a timely manner.
Knowledgeable staff
available to support
customers.
Systems enable
connections/relocations
of plant etc to be
tracked and reported
on. KPI returns accurate
and show an
understanding of
regulatory requirements;
data sources
transparent, auditable.
Complaints of delay
very few in number –
and readily explainable
where they occur.
Innovative ways to
shorten the process/
improve the customer
experience being
introduced.
Table 13: Network Connections Assessment Criteria
Special Needs Code of Practice
Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to the
Special Needs
CoP (All
companies have
a Code).
Licence condition
No well-documented
register; reliance on the
knowledge of individual
staff about the needs of
those customers with SN
(e.g. during outages,
when dealing with
Register in place. Not
always easily accessible
to all those staff who
need to be aware (e.g.
CC, Distribution,
Collection, Service
provider for MRBC).
Register in place.
Includes appropriate
numbers of customers.
Accessible but not all
staff familiar with what it
means for their work.
Some examples of
Register in place,
accessible to all staff
who might need to be
aware. Includes
appropriate numbers of
customers. Evidence
that effort has been
Register in place, readily
accessible to all staff
who might need to be
aware. Includes
appropriate numbers of
customers.
Integrated with other
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Assessed level of
compliance 1 2 3 4 5
42 „
arrangements by
which special
services for
customers who
are disabled,
chronically sick,
have limited
income or of
pensionable age,
can be made
available, where
appropriate …‟
payment and
disconnection issues).
No or limited or
evidence of a
systematic process for
registering those with SN;
or keeping in touch
regarding their needs.
CoP available but not
promoted (on website,
printed copies available
on request only). Relies
on customer to initiate
contact
Includes limited numbers
of customers with
limited/incomplete
information on each.
Often relies on
customer‟s initiative to
secure help (e.g. during
outages).
CoP available but not
well promoted (on
website, some printed
copies available at
some braches/service
centres).
Little outreach activity;
relies on SN customer or
someone on their
behalf, approaching the
company.
Plans for improvements
in development but not
actioned.
incomplete information
on each SN customer.
Sometimes relies on
customer‟s initiative to
secure help (e.g. during
outages).
CoP available, well
presented but not well
promoted beyond the
company‟s
website/offices.
Some, but limited,
examples of outreach
activity.
Plans for improvements
prepared; some
progress in
implementation not all
are actioned.
made to identify all
appropriate customers.
Integrated with some
systems (typically CRM,
but not others e.g. GIS)
most staff are aware of
SN when considering
actions which might
affect SN.
Readiness plan for
active support during
outages.
Outreach programme in
place (routine contact
with Ministries, health
providers and others
with knowledge of SN)
and awareness
programme (briefing of
parties, newspaper
advertisements,
roadshows etc)
Regularly keeping in
touch with SN to update
register and supporting
information.
systems (CRM, GIS) so
that staff are
immediately aware of
SN when considering
actions which might
affect SN.
Comprehensive plan for
proactive support during
outages.
Comprehensive
outreach programme
(routine contact with
Ministries, health
providers and others
with knowledge of SN)
and awareness
programme (briefing of
parties, newspaper
advertisements,
roadshows etc)
Timetable for keeping in
touch with SN to update
register and supporting
information.
Innovation in Code
implementation.
Table 14: Special Needs Code of Practice - Assessment Criteria
Outage management
Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to
No formal process for
communicating with
Liaison with distribution
business in place to
Advance notification
from distribution business
Advance notification
from distribution business
Advance notification
from distribution business
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Assessed level of
compliance 1 2 3 4 5
communication
with customers
during planned
and unplanned
network outages.
distribution business or
system control.
Contact centre not
aware of system
outages, unable to
answer customer
queries.
No proactive customer
notifications of planned
outages.
some extent.
Advance information f
planned outages.
Contact centre aware
of system outages, able
to respond to customer
queries and complaints
Some evidence of
proactive customer
contact in advance of
planned outages.
and network control
centre of planned
outages, listing network
affected, reason, date,
time and expected
duration of outage.
Notification to local
media for broadcasting
in advance of day and
on day of outage.
Arrangements for
contact with special
needs customers in
advance of outage (see
special needs above)
and network control
centre of planned
outages, listing network
affected, reason, date,
time and expected
duration of outage.
Notification to local
media for broadcasting
in advance of day and
on day of outage.
Regular updates on
progress of outage and
updates on reasons fro
any over-run.
Arrangements for
contact with Special
Needs Customers in
advance of outage (see
special needs above)
and network control
centre of planned
outages, listing network
affected, reason, date,
time and expected
duration of outage.
Notification to local
media for broadcasting
in advance of day and
on day of outage.
Regular updates on
progress of outage and
updates on reasons fro
any over-run.
Arrangements for
contact with Special
Needs Customers in
advance of outage (see
special needs above)
Use of all available
technology to reach
customers, including IVR,
website, social media
and SMS messages to
customers with known
contact details.
Integration or shared
systems with network
control centre.
Table 15: Outage Management (Customer communications) - Assessment Criteria
Quality of frontline advice
Assessed level of
compliance 1 2 3 4 5
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Assessed level of
compliance 1 2 3 4 5
Descriptor as it
applies to
connecting
customers to the
network.
It has not been practical to rate companies as rigorously as in other areas, given that we have not compared the traditional organisational form (in
which the local branch or service centre is the primary customer interface) with the Blueprint (which envisages the contact centre as the primary – and
in the longer term single) customer interface. In the text we have provided a review based on our visits but have not reviewed, evaluated or ranked the
two different approaches.
See commentary in the report for more detail.
Table 16: Quality of Front Line Advice - Assessment Criteria
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10 Appendix 4: Comparison of Existing Contract Features
Company O Company I Company S Company D Company C
Contractor Company Y Company Y Company Y Company X Company Y
Scope of Services Meter reading, Bill
production, bill
delivery, payment
collection
Meter reading, Bill
production, bill
delivery, payment
collection
Meter reading, Bill
production, bill
delivery, payment
collection
Meter reading, Bill
production, bill
delivery, payment
collection
Meter reading, Bill
production, bill
delivery, payment
collection,
disconnection
Type of contract “Factoring”
Agreement
Fee Based Fee Based Fee Based Fee Based
Number of Actual meter reading as percentage of active
customers/scheduled meter readings
None Incentives and
Penalties
Incentives and
Penalties
Incentives and
Penalties
No information
% age of bills printed and delivered within 30 days of meter
reading date
None None None Incentives No information
% age of collected meter readings on customer cards None None Incentives and
Penalties
None No information
Number of validated complaints None Penalties Penalties Penalties No information
%age of valid reminders notices issued in timely manner None None Incentives and
Penalties
Incentives No information
Deposit collections promptly None Penalties Penalties Penalties No information
Incorrect meter readings None Penalties Penalties Penalties No information
Meters to be read at least once in 3 months None None Penalties None No information
CT meters not read in month None None Penalties None No information
New connections – read within 45 days of connection None None Incentive None No information
Discrepancies between reads and bills None None Penalties None No information
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Company O Company I Company S Company D Company C
Wrong reading or bill calculation for more than 12 months None None Penalties None No information
Reading to bill cycle None None Penalties None No information
Replacement of poor performing contractor staff None None Penalties None No information
Replacement of meter readers resigning None None Penalties None No information
Meters without barcode None None Penalties None No information
Obtaining mobile numbers None None Incentives None No information
Reporting defective meters and illegal connections None None Incentives and
Penalties
None No information
Disconnections & Reconnections per list None None Incentives and
Penalties
None No information
Disconnection and reconnection time None None Penalties None No information
Employee incentive scheme in place None None Penalties None No information
Data synchronisation None None Penalties None No information
Table 17: Comparison of existing MRBC contract arrangements
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11 Appendix 5: Proposed Template for AER KPI returns
Jan Feb Mar Q1 Apr May Jun Q2 Jul Aug Sep Q3 Oct Nov Dec Q4 Year
Number of validated meter
readings in month195000 180000 189500 564500 188000 187000 186500 561500 188000 192500 196000 576500 201000 201450 201950 604400 2,306,900
Number of customers in class at
quarter end200000 200700 201500 201500 202400 203100 204050 204050 205050 206000 206650 206650 207100 207350 208300 208300 208300
% achieved 98 90 94 93 93 92 91 92 92 93 95 93 97 97 97 97 92
Number of validated meter
readings in month1 2 3 6 4 5 4 13 4 5 4 13 7 5 6 18 50
Number of customers in class at
quarter end4 4 5 5 5 5 6 6 5 5 6 6 7 8 8 8 8
% achieved 25 50 60 40 80 100 67 72 80 100 67 72 100 63 75 75 52
MR3Number of validated meter
readings in month1 2 3 6 4 5 4 13 4 5 4 13 7 5 6 18 50
Number of customers in class at
quarter end4 4 5 5 5 5 6 6 5 5 6 6 7 8 8 8 8
% achieved 25 50 60 40 80 100 67 72 80 100 67 72 100 63 75 75 52
MR4Number of meters not read at any
time in quarter5 4 6 12
MR5Number of meters not read at any
time in year 1300 1240 988 1400 1203 1300 850 1300 1400 1235 1234 1100 1100
MR6
Longest elapsed period for any
customer since last validated
meter reading (months)
120 119 117 115 104 100 99 95 88 72 61 43
MR1
MR2
Table 18: Sample proposed workbook for meter reading KPI returns
Companies to enter numbers in yellow shaded cells only. The calculations are in locked cells