The Ohio Development Services Agency (ODSA) issued a notice to agencies on Monday announcing its decision to delay the enforcement of income reverification requirements for the Percentage Income Payment Plan until January 1, 2020, at which point it will begin dropping people from PIPP for failure to reverify. ODSA commits to reviewing the decision in December and may adjust the date based on the situation consumers are then facing because of the COVID-19 pandemic.

This clearly benefits our clients, particularly those that are homebound because of illness or susceptibility to COVID-19. It will also affect relatively few existing clients because most will reverify when they apply for a WCP or regular HEAP payment.

The other issue is anniversary date compliance, the requirement that all missed PIPP payments be made up or the customer is dropped from the program. According to the ODSA email, anniversary date drops and disconnections for nonpayment are the purviews of the utilities.

AEP intends to shift the anniversary dates that fell during the pandemic forward to October, and will then begin the process of removing customers from PIPP because of missed PIPP payments. However, those customers may take advantage of the Winter Reconnect Rule. If the customer pays the $175, all the missed PIPP payments will be rolled into the existing arrears and eligible for incentive credits. Put another way, if clients missed PIPP payments, they can use the Winter Reconnect Order and the missed PIPP installments will be treated as pre-PIPP arrears.

I think the approach works for our customers. However, the other electric utilities – DP&L, FirstEnergy – and Duke, the only combination utility, have yet to provide clarity on how the anniversary date issue will be treated. One of the reasons the utilities’ policies will look different has to do with their billing systems. Programming PIPP is a pain, and every utilities’ software has some degree of limitations when it comes to altering dates. I think we’re all aware that some utilities haven’t even been able to remove disconnection notices from bills.

The PUCO has instructed the gas utilities to simply suspend reverification and anniversary dates until it directs otherwise. PIPP payments missed between mid-March and the restart of disconnection notices will roll forward into arrears and be eligible for crediting. See the chart for disconnection dates and other details of utility transition plans:

Dominion East Ohio recently filed a letter indicating its billing system cannot distinguish between payments missed prior to March 15th and those missed after that date so it will roll all missed payments into the arrearages. This is effectively the same approach AEP is taking and in both cases, it is because of the limits of their billing systems. Since we work with OCEAN, we are all well aware that software has its challenges.

Reverification and anniversary date issues are really limited to existing PIPP or Graduate PIPP clients. They will not be issues for the newly poor that will represent the bulk of our increased caseload. When word gets out that disconnections are starting, families will find us. We know agencies are doing outreach and many areas have vibrant referral networks among nonprofits. 211 and other outreach efforts will get the clients to us.