u-18486 dte electric and dte gas report on billing practices

January 22, 2018

Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, Michigan 48917

RE: In the matter, on the Commission’s own motion, to require DTE

Electric Company and DTE Gas Company to investigate and to submit a report to the Commission Staff regarding each utility’s billing practices MPSC Case No: U-18486

Dear Ms. Kale:

Attached for electronic filing is the DTE Electric Company’s and DTE Gas Company’s Report in compliance with Commission’s Order of December 20, 2017 in the above matter.

Very truly yours,

David S. Maquera DSM/lah Encl.

DTE Energy CompanyOne Energy Plaza, 688 WCB Detroit, MI 48226-1279

David S. Maquera(313) 235-3724 [email protected]

1

DTE Electric Company and DTE Gas Company BILLING PRACTICES REPORT U-18486

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Contents

Introduction ..................................................................................................................................... 3

1. Shutoffs History 2016 and 2017 ................................................................................................. 5

2. Wrongful Disconnection Error Rate ........................................................................................... 7

3. Verification Process Prior to Shutoff .......................................................................................... 8

4. C360 System Impact on Shutoffs ................................................................................................ 9

5. Wrongful Disconnections ........................................................................................................... 9

6. Shutoff communication efforts ................................................................................................. 10

7. DTE Energy Plans Going Forward ........................................................................................... 10

Conclusion .................................................................................................................................... 10

Attachments 1 through 5

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Introduction DTE Energy (“DTE” or the “Company”)1 lives by its seven core values, which includes: “We see our work through the eyes of those we serve… and know that our work is powerful means to serve others.” Accordingly, DTE uses the lens of its values in the decision making of the development, implementation, and processes used to serve its communities to provide safe, reliable, affordable, and sustainable electric and gas service. In April 2017, DTE transitioned to a SAP technology platform referred to as Customer 360 (“C360”). This customer relationship and billing platform represents one of the most significant technology upgrades in the Company’s 150-year history. C360 streamlines 130 separate end-of-life software systems into one comprehensive platform. DTE contracted hundreds of customer service representatives and spent five years planning for the transition to C360 to maintain the Company’s high standards of service. Notwithstanding DTE’s preparations and its comparatively successful implementation, DTE recognizes that in the process of transitioning 3.4 million customers to a brand-new platform that some customers experienced billing issues. These issues have impacted the quality of customers’ service including wrongful service disconnections due to C360 billing defects. DTE is committed to making this right. On December 20, 2017, the Michigan Public Service Commission (“MPSC” or the “Commission”) issued an Order in MPSC Case No. U-18486 requiring DTE Electric Company and DTE Gas Company to investigate and submit a report addressing concerns related to each utility’s billing practices. Specifically, the Commission required the report to:

1. Provide DTE’s performance history regarding shutoffs from January 1, 2016 through the present, highlighting the transition period for C360, provide the number of customers shut off by each month and, in the interim, continue to report weekly shut off numbers to the Staff.

2. For the time period prior to the implementation of C360, provide DTE’s typical error rate for wrongful disconnection and any information DTE has on the industry standard.

3. Provide an explanation of the verification process DTE performs prior to disconnecting a customer.

4. Provide an explanation of the impact of C360 on shutoffs since the implementation, including details on the type of defects, identifying when defects were fixed, and the number of customers impacted by month by each defect.

5. Review with the Staff a list of customers who were improperly shut off, reason for shutoff (i.e.: C360 no bill, C360 bill presentation, AMI scheduling and MPSC open informal

1 Both DTE Electric Company and DTE Gas Company are wholly-owned subsidiaries of DTE Energy.

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complaint, etc.), restoration length of time from disconnect, and any remedy provided to customer.

6. Outline DTE’s customer communication efforts regarding shutoffs with details that include how and what information was communicated to customers who had been improperly shut off.

7. Provide an explanation of DTE’s plans going forward to address all improper shutoffs. As directed by the Commission, DTE submits this Report providing the Company’s performance history related to shutoff and billing practices as well as detailing our plan and commitment to zero cuts in error.

5

1. Shutoffs History 2016 and 2017 Provide DTE’s performance history regarding shutoffs from January 1, 2016 through the present, highlighting the transition period for C360, provide the number of customers shut off by each month and, in the interim, continue to report weekly shut off numbers to the Staff. There are four (4) distinct scenarios/processes where DTE would initiate a shutoff of services (discontinuance of utility service that is not requested by a customer).

In March of 2017 we began our C360 transition and discontinued collection activities and customer shutoffs. We resumed collection activities in mid-May of 2017.

a) Customers physically discontinued due to non-payment: 243,504 shutoffs in 2016 and 153,889 in 2017

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b) Customers physically discontinued due to customer denying DTE access to the Company’s

equipment to switch their analog meters to AMI (Advanced Metering Infrastructure): 34 shutoffs in 2016 and 653 in 2017

c) Customers physically discontinued due to customer denying DTE access to the Company’s equipment to move inside meters outside as part of the MMO/MRP programs (Meter Move Out/ Main Renewal Programs): 552 shutoffs in 2016 and 112 in 2017

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d) Customers physically discontinued due to unauthorized use of utility service: 44,495 shutoffs in 2016 and 9,796 in 2017

Going forward, we will continue to provide customer shutoff data to the MPSC Staff at our weekly check in meetings. 2. Wrongful Disconnection Error Rate For the time period prior to the implementation of C360, provide DTE’s typical error rate for wrongful disconnection and any information DTE has on the industry standard.

2016 wrongful disconnection error rate: 0.12% DTE’s typical error rate for wrongful disconnection is based on billing and noticing issues. In 2016, there were a total of 295 wrongful disconnections. Based on the total of 243,504 total customers physically discontinued due to non-payment in 2016, this represents a very small fraction of our customers (0.12% error rate). C360 wrongful disconnection error rate: 0.26% During the eight (8) months period following the April 2017 C360 implementation from May through December 2017, there were a total of 252 wrongful disconnections out of a total of 101,745 customers physically discontinued due to non-payment and a total of 18 wrongful disconnections out of a total of 653 customers physically discontinued due to denied access to switch the analog meter to AMI. No customers have been erroneously disconnected due the MMO/MRP project and due to the unauthorized use. Industry standard wrongful disconnection error rate: 0.25%-0.65% Accenture informal survey process of North America utility companies of relative size, composition and complexity as DTE show an average error rate for wrongful disconnection ranged from 0.25% to 0.65%. Due to the sensitive nature of the information requested as well as the informal data collection procedure, the participating utility companies have chosen to remain anonymous. The letter from Accenture has been included as Attachment 1.

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3. Verification Process Prior to Shutoff

Provide an explanation of the verification process DTE performs prior to disconnecting a customer. a) Customers physically discontinued due to non-payment A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 2.

The process map that DTE follows for the Collection of Residential Accounts is included as Attachment 2. This process is designed to ensure that we strictly follow the guidelines that we have set in place for the billing, notification, collection, and disconnection of our Residential Customer Accounts. This process is robustly designed to create a set of checks and balances to provide every opportunity for our customers to avoid an interruption of their utility service. This process is also designed to give DTE an opportunity at many steps in the process to ensure that only customers who have not met the required obligations to DTE continue through to the next steps of the collection process. While we have found that a small number of errors have occurred in this process recently, the appropriate changes have been made to prevent those same errors from occurring in the future. These changes include: 1) the development of built-in rules and embedded tests that allow customers to advance through the collection flow and service orders to be sent to the field for disconnection; 2) a disconnection audit report, developed late 2017 and implemented in January 2018 that will perform additional checks and flag potential wrongful shutoffs to be manually reviewed. This process is designed to mitigate any improper service interruption for our customers and to ensure compliance with the MPSC’s billing practices. b) Customers physically discontinued due to denied DTE access to switch their analog meters to

AMI A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 3.

Given the significant impact of cuts to DTE’s residential and commercial customers, the Company takes the process under which the AMI-related cuts are executed very seriously. In particular, the Company’s goals with this process are that it is followed consistently in every instance and that it also eliminates any potential errors via various checks along the way. This is accomplished by the development of and adherence to a detailed process map (see Attachment 3), which was designed with clear lines of responsibility. In addition, there are a number of embedded tests built into the process with the intent to highlight any anomalies so as to avoid any AMI-related cuts in error. Where some of these cuts in error have occurred in late 2017, the process map was modified accordingly in order to prevent such instances from occurring in the future. This process map has been rolled out to the various process owners within the process and it is posted in many locations to ensure that everyone is clearly aware of the expectations.

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c) Customers physically discontinued due MMO/MRP project (Meter Move Out/ Main Renewal Program)

A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 4. No customers have been erroneously disconnected in this process during the period under review. d) Customers physically discontinued due to unauthorized use of utility service A process map highlighting the verification process DTE performs prior to disconnecting a customer is included as Attachment 5. No customers have been erroneously disconnected in this process during the period under review.

4. C360 System Impact on Shutoffs

Provide an explanation of the impact of C360 on shutoffs since the implementation, including details on the type of defects, identifying when defects were fixed, and the number of customers impacted by month by each defect. Below is a list of the C360 system defects that affected collection processes and potentially caused a wrongful disconnection, including the number of customers impacted by month:

5. Wrongful Disconnections

Review with the Staff a list of customers who were improperly shut off, reason for shutoff (i.e.: C360 no bill, C360 bill presentation, AMI scheduling and MPSC open informal complaint, etc.), restoration length of time from disconnect, and any remedy provided to customer.

C360 System Defect Description Fix date Jun Jul Aug Sep Oct Nov Dec Total

Disconnection Workflow not cancelled on reconnection order 6/12/2017 4 0 0 0 0 0 0 4

Customer incorrectly disconnected with Flag for Red Bill in Waiting

print status6/16/2017 21 0 0 0 0 0 0 21

Payments incorrectly accepted when collection cut order is in

Onsite / Enroute status8/18/2017 5 27 7 0 0 0 0 39

Unprinted invoices not excluded from the collection process 10/6/2017 1 4 3 1 1 0 0 10

Incorrect shut off date when Subsequent Red Bill reached before

Flag for Red Bill is printed10/27/2017 5 51 21 5 1 0 0 83

Incorrect shut off date on Red Bill 12/8/2017 3 39 27 23 2 1 0 95

Total 39 121 58 29 4 1 0 252

Number of customers wrongfully shutoff

10

DTE personnel met with Staff on Tuesday, January 16, 2018 and Friday, January 19, 2018 to review the list of customers who were improperly shut off, reason for shutoff, restoration length of time from disconnect and remedy provided to the customer. 6. Shutoff communication efforts Outline DTE’s customer communication efforts regarding shutoffs with details that include how and what information was communicated to customers who had been improperly shut off. No communication was completed after the wrongful disconnections took place, except the restoration interactions. Once improper shutoffs were identified restore events were escalated and processed same day.

7. DTE Energy Plans Going Forward An explanation of DTE’s plans going forward to address all improper shutoffs. The new C360 system has built-in rules and embedded tests that allow customers to advance through the collection flow and service orders to be sent to the field for disconnection. Additionally, as a double check, a disconnection audit report was developed late 2017 and implemented in January 2018. This report will perform additional checks and flag potential wrongful shutoffs, cancelling the disconnect service order. Manual reviews will also be performed to prevent wrongful shutoffs in the future. Conclusion Utility billing and shutoff processes are established and enforced by MPSC. DTE adheres to these billing rules and utilizes a strict internal process for recognizing non-payment, notifying customers of intent to disconnect at several junctures, and ultimately disconnecting service. Defects in the new C360 billing platform did disrupt our normal billing processes and resulted in isolated incidents of wrongful disconnections. In these cases, customers either did not receive a bill or did not get correct notification of the shutoff process, but were still disconnected. The majority of these disconnections have been restored to normal service and most were restored on the same day. DTE recognizes the impact of the service interruptions and understands that this is a serious inconvenience for its affected customers. DTE’s customer service teams are working diligently to correct any outstanding billing issues resulting from the C360 transition. The disconnect process has been error-proofed by implementing measures such as a manual process for double-checking accounts flagged for disconnect by the software. These checks will ultimately be automated to ensure defects of this type are eliminated.

Accenture LLP

140 Fountain Pkwy N

Suite 400

St. Petersburg, FL 33716

www.accenture.com

January 15, 2018 DTE Energy 1 Energy Plaza Detroit, MI Re: Disconnect (for NonPay) in Error To Whom It May Concern: DTE Energy asked Accenture to research the industry-wide best practices benchmarking around the “Disconnect in Error” and/or “Disconnect Without Proper Notification” metric. Accenture ran an informal survey process to query top North America utility companies of relative size, composition and complexity as DTE Energy. Based on this informal process, we saw that the average “Disconnect in Error” metric ranged from .25% to .65% with varying degrees of inclusions/exclusions from the rule. Due to the sensitive nature of the information requested as well as the informal data collection procedure, the participating utility companies have chosen to remain anonymous. Sincerely, Dondi Schneider Managing Director North America Utilities SAP Lead Accenture

MPSC Case No. U-18486 DTE Electric & DTE Gas Billing Practices Report

Attachment 1 Page: 1 of 1

Process Collections for Residential Accounts

SA

P C

R&

BS

enio

r A

nal

yst

Cus

tom

er S

ervi

ce

Bu

sin

ess

Su

pp

ort

IT

Reminder Call Sent to collection

agency – Robo/Live callNotice of intent letter

sentRed shutoff bill statement sent

Day 25 Day 27 Day 30 Day 40

Start

Day 21

Red shutoff bill Due

Day 44

Create disconnect document

Day 45

Invoice is sent Invoice is due

Day 1

Is the customer past due balance

<$100

No

End

Yes


<$100


<$100

Is the customer past due balance <$100


<$100


<$100

End End End End End

Yes Yes Yes Yes Yes

No No

No No No

Create disconnect report


<$100

Yes

Reset dunning step to remove from

disconnect statusEnd

NoIs there 10 days between the

shutoff date and red shutoff bill statement print date?

Yes

Reset dunning step to remove from

disconnect status

No

End

End



Process Non-Pay Disconnects

SA

P C

R&

BF

SA

/OP

A/S

ervi

ce S

uit

e/A

MI

Create Disconnect Document

Create Order (Electric and Gas)

Response Received

Interface

Reschedule Next Business Day (Expiry

Date in Future)

Order Assignment + Schedule for Disconnect

Worked? Complete?Yes

No

No

Yes Combo Customer? YesOnly One Service

Off?

No

No

Yes

Reschedule for +7 Days

Perform Non-Pay Move Out

(+7)

End

Manual scheduling by workload

Interface

Day 45Day 46



AMI Cut Process

RM

&P

Fie

ld a

nd

Off

ice

AM

I Ins

talla

tio

ns

Elec

tric

Fie

ld

Ope

rati

on

s (E

FO)

Ove

rhea

d an

d

Un

der

grou

nd

Met

eri

ng

and

B

illin

g

Mai l Cordial Letter with

$50 Incentive to Customer

First Cut Letter sent to

Customer with $50 Incentive

Customer Respond in 7

Days?

Customer Respond in 7

Days?

Second Cut Letter Sent 5 Prior Days to Executing Cut

Customer Respond?

AMI Sends Cut List to RM&P to

Schedule Cut

Receives Cut List from AMI

Crew Executes Cut

Customer Accepts AMI or OPT Out

Meter?

Crew Leaves Notice at Site to Call RM&P for

Restoration Along with Safety Notice

Coordinates with Lines and EFO to Form Super Crew

EFO Installs Meter

Customer Cal ls RM&P for Restore?

Service Remains Off

YES

System Updates with Install information

Order Sent to EFO for AMI or OPT Meter Install

YES

Meter Installed and Refer order to OH/UG

Lines

Field Completes Restore within 2 Days of Receipt

YES

Analyze Account for

Meter Change

Verify account is Eligible for

Cut

Hold on Customer account?

Analyze Accounts and establish final

cut list

List Sent to Customer

Strategy for Dunning hold

NO

Account Held >24 hours?

Super Crew Arrives at Site for Install or

Cut NO

NO

YES

Customer Present?

END

AMI Meter Visible?

YES

AMI Team Verified AMI Meter Exist?

NO NO

Escalate or Restore

YES

Service Cut in Error?

Analyze Accounts for

multiple install at tempts

Notify Marketing &

Reg Rel of Cut Locations

NOMeter

Installed?

YESYES

END

NO

ET – Billing Informs AMI that Orders from Completion List have been Processed in CR&B and any SO25's have been worked

All Countermeasures are Highlighted in Yellow

Was Letter Returned?

Research Address and re-mail letter

YES



Init iate AMI Appointment

Process


Process


Process

Yes

NO

Sent to AMI Team: Dunning, Senior, Customer in Complaint

Process, Medical Alert

Account Removed from

Cut List

Verify Cut Order Still Valid

YES

Return to AMI Installation

NO

NO

END

YES

YES

Does order exist from another

Channel?NO

Perform Wellness Check

NO

YES

YES

NO

System Updates with Install information

Bill Issued to Customer?Reconcile Billing

NO

EndYes

NO



YES

NONONONO

Investigate Order Creation

YES

Updated: 1/12/18 v.6



Printed documents are considered uncontrolled. Verify current version prior to using.

True North: All (100%) impacted customers notified prior to DTE arrival.

Ass

et

Ma

nage

men

t O

pera

tions

A

nal

yst

MM

O /

MR

P C

onst

ruct

ion

Ope

ratio

ns A

naly

stC

rew

Lea

der

MM

O C

rew

Phase 3Phase 1 Phase 2

12Process Outputs:

Description: This is the process and the escalation for notifying customers impacted by the Gas Renewal Program.

Process Owner: Nachell GregoryLast Updated: 01/12/2018Review Cadence: Quarterly

TITLE: GRP Customer Communication and Letter Escalation Process Map

Metrics: Customers notified accordingly and timely.

Annotation Box

Decision ActivityStart/End Escalation

Out going to another

page

Incoming from

another page

Process Legend: ‐ Displays the desired path ‐ Escalation connection ‐ Connection‐ On page ConnecterX

Activity using

Document

Data Base

DataSub Process

Value Analysis Coding:

Waste

Not value added but necessary

Value Added

ET

Submit Mail Request for Program Letter

to impacted customers.

(30 days prior to Constructionl)

Make customer contact & schedule

appointment

Appointment Successful?

Attempt to make appointment with

Customer

Appointment Successful? (Repeat min. of three

times)

No

Crew completes Meter Move Out.

Yes


Wait Ten Calendar Days

Yes


Yes

Call Customer phone number(s) in C360 24 hours

Prior to service cut and cap.

Document C360 that call was made

to customer.

No

Customer Contact made

& Work Scheduled?

Yes

Cut and Cap service.

No

Yes

No

Update Customer Acct in C360 Final

Notice was left.

Scouting Letters Mailed to Impacted Customers

Program Letters Mailed to Impacted Customers

End

3 Door Hangers Left with Impacted Customers

Restoration complete?

Restoration Care Door Hanger Left

Restoration Season Door Hanger Left

Yes

No

Scout Assigned Location

Leave 10-Day Final Notice

(Notice of Gas Service

Interruption)

No

Leave “Sorry We Missed You“ Door

hanger



Theft Process V1

BPE

M C

ase

Bu

sin

ess

Un

itSe

rvic

e O

rder

Serv

ice

Suit

e

Author: Jampana

RAT Call/CR Thermal Imaging Detectant/TDIID Fraud AMI TheftTheft Internal ProspectingCorporate Security/

Compliance

Mtr Reads, EFO/GFO, Coll Reps,

DO

R728 R723 R745

R961 R959 R976

More Than 30 days old ?

CloseYes

R730

Customer Request?

R768(RAT)

R732(Thermal Imaging)

R734(ID Fraud)

R976

R735(AMI)

R758(Theft Escaltion)

Yes

R730(Theft Internal)

NO

R753(Prospecting)

Theft Work Order

R738(Corporate Security)

1To Page 2



Theft Process V1

Serv

ice

Ord

er

Serv

ice

Suit

eB

PEM

Cas

e(T

hef

t B

illin

g)M

axim

o

Serv

ice

Suit

e

Author: Jampana

Theft Work Order

Internal Theft Billing

N108

Generate R733/R371 Pole cut for electric or R370 for Gas

Generate R736 – Apt BldgNo action unless refer to cut is

Y

Moveout Customer, Update meter end date, update Disc reason to Theft, Update Site Level Security Block, Create

Interaction Record

Update Meter status to

Disconnected.(Will be turn on for other

account/BP)

Moveout Customer, Update meter end date, update Disc reason to Theft, Update Site Level Security Block, Create

Interaction Record

Update meter status to S-SealedUpdate Disc Reason to Theft

Update Site Level Security BlockCreate Interaction Record

Refered to Cut?

Referral

End

NOElectric/

GasYes

Service Order – MAT Code R733/R744(Pole Cut)

Electric

Active/InActiveGAS

Service Order – MAT Code R370(Maximo)

Active

Meter Exists?

InActive


Yes

Unmeter Observed?code = 95??

NO



Yes

NO

Maximo Theft Work Order

CUT_CAP

NOCUT

LOCK_METER

CUT_REMOVE

METER_REMOVE

Update Service StatusInteraction Record

No ActionClose Service Order

End

End

01 – No Cut

55 – Pole Cut

30 –Theft Drip Cut

99 – Theft Removed Drop

Theft Work OrderSecured Completion Code(Service Level)

2To Service

Suite

3To Maximo

2From Service

Order(Referrel)

3From Service Order(Referr

el)

1From Page 1

Service Disconnected



10 Disconnect Meter20 – Meter Removed/

Meter moved check is X50 – Steal Remove60 – Turn on Taken95 – Unable to Secure

30 – No Theft/No action

98 –Refer to Apt Bldg investigation



Theft Process V1

BP

EM

Cas

eB

usi

nes

s U

nit

Serv

ice

Ord

erSe

rvic

e Su

ite

Max

imo

Author: Jampana

RAT Call/CRThermal Imaging

Detectant/TDIID Fraud AMI TheftTheft Internal ProspectingCorporate Security

Mtr Reads, EFO/GFO, Coll

Reps, DO

R728 R723 RXXX

R961 R959 R976

More Than 30 days old ?

CloseYes

R730

Customer Request?

R768(RAT)

R732(Thermal Imaging)

R734(ID Fraud)

R735(AMI)

R758(Theft

Escaltion)

Yes

R730(Theft Internal)

NO

R753(Prospecting)

Service Suite Theft Work

Order

R738(Corporate Security)

Disconnect Complete OR Referrel?

Service Suite

New ReferrelMaximo/Service Suite

Referrel

MaximoTheft Work

Order

Maximo

Internal Theft Billing

108

Disconnect Completed/Theft Found and requires Billing

Create new Service Order



u-18486 dte electric and dte gas report on billing practices

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