As you know, many of the new data collection requirements were integrated in
ServTraq in preparation for the first planned implementation in March. Naturally,
complete implementation cannot occur until the Data Transfer Rules and
associated documents are finalized. ServTraq staff spent many hours
trying to refine the requirements to fit in better with current service
delivery processes. Because of the constant delay at CSD, this has been
needlessly costly. In an effort to avoid a repetition of this situation, we are
instituting a policy that we will implement changes to the front end system no
sooner than 30 days after the Data Transfer Rules are finalized. We assume that
the rules are not final until an implementation date is set and reflected in
the DTRs and they are signed. The implementation date is the date that all
transfers (live) into the CORE or Weatherization Data Repository systems
(Production, not testing) will be subject to the rules and rejections will
occur based on the rules in the final DTRs. CSD has been notified of this
policy and we will elaborate on it in future emails.
Recommeded Changes/Comments to Draft DTRs Late Friday afternoon, CSD released what may be the final draft of
the Data Transfer Rules - now version 3.9.2. Comments will be accepted until
noon this Friday (8/26), with the final anticipated to be released by 5
p.m. on the same day, and an October 1st implementation date.
CSD’s website was offline yesterday so we delayed sending this notice.
Below are the problems that we have brought repeatedly to CSD and CSD’s
Technology Steering Committee that still remain. If you agree with our
comments, please copy the numbered items into an email to Ron Robinette before
noon on Friday, August 26th. Links to the current DTRs, provided by CSD, listed
at the end of this email.
1. Deviation from Transfer Rules
Eight fields now carry a “Validation” criteria indicating that “If utility code
is 1 (Included in Rent) or 2 (Submetered), populate field from “fieldname xxx”
field.” This is not a validation. It is a demand for a front end process that
could just as easily be met by CSD after the transfer. The database transfer
rules should be exactly that - rules that validate the data received from LSPs
and must be used for the independent development of local data collection
systems. Since there is no validation or indication that CSD system will reject
a record without the specified population, the data transferred will not be
reliable.
Ron Robinette’s Response: You are correct that the record will not be
rejected; however there is validation in CORE. The validation ensures
that the “fieldname xxx” matches. When they do not match, CORE will
populate field from “fieldname xxx” field.
Change Recommendation: This was not made clear in 3.9.2. Simply adding
“CORE will populate …” In each case would suffice. DTRs address validations and
not population of fields in front end systems.
2. WPO Vendor Validation
The solution reflected in the DTR for the need to collect data for federally
required reports on the top WPO vendors in the state is burdensome to LSPs and
will not render reliable data. No basic validation of a WPO vendor exists. The
system will accept any account number for any WPO vendor for any applicant. The
record for an applicant in San Diego County receiving propane from AmeriGas
could reflect that the vendor was “Siskiyou Garden Apartments” or “Leo S Jones”
as readily as it could “Propane Utility”.
Ron Robinette’s response: This is not new. The top 20 Propane and Oil
vendors are validated against a list of vendors provided by the LSP community.
After a year of collecting data we can look at whether it would be beneficial
to further validate account number for greater accuracy. Other than the
reporting of company name, we are not requiring any changes from our vendors at
this time but feel free to raise any concerns with the Energy Division if you
believe a new way to validate is needed.
Change Recommendation: This is a complete waste of staff time that front
end systems may not mitigate. There is complete agreement that there is no way
to assure any integrity in this data and that it is only a burden on the LSPs,
yet it is still part of DTRs. In February ServTraq staff made a recommendation
to collect a “Top 20 WPO” report from LSPs from front end payment records
rather than place the burden of double entry on LSPs. Our recommendation still
stands as it would adequately fulfills the new federal reporting requirement
with the least impact on LSPs.
Julie Garcia
CORE Transfer Changes
We’ve been working with CSD’s IT and Program Sections to finalize the Utility Assistance Data Transfer Rules (DTR) document since last year. The Data Transfer Rules specify the requirements that must be included in ServTraq© for CORE UA record compliance. The need for this change is a change in federal reporting requirements that took effect last year for seven new fields of data. March 1, May 1 and August 5 implementation dates have all passed since the final DTR 3.9.
As you know, many of the new data collection requirements were integrated in ServTraq in preparation for the first planned implementation in March. Naturally, complete implementation cannot occur until the Data Transfer Rules and associated documents are finalized. ServTraq staff spent many hours trying to refine the requirements to fit in better with current service delivery processes. Because of the constant delay at CSD, this has been needlessly costly. In an effort to avoid a repetition of this situation, we are instituting a policy that we will implement changes to the front end system no sooner than 30 days after the Data Transfer Rules are finalized. We assume that the rules are not final until an implementation date is set and reflected in the DTRs and they are signed. The implementation date is the date that all transfers (live) into the CORE or Weatherization Data Repository systems (Production, not testing) will be subject to the rules and rejections will occur based on the rules in the final DTRs. CSD has been notified of this policy and we will elaborate on it in future emails.
Recommeded Changes/Comments to Draft DTRs
Late Friday afternoon, CSD released what may be the final draft of the Data Transfer Rules - now version 3.9.2. Comments will be accepted until noon this Friday (8/26), with the final anticipated to be released by 5 p.m. on the same day, and an October 1st implementation date. CSD’s website was offline yesterday so we delayed sending this notice.
Below are the problems that we have brought repeatedly to CSD and CSD’s Technology Steering Committee that still remain. If you agree with our comments, please copy the numbered items into an email to Ron Robinette before noon on Friday, August 26th. Links to the current DTRs, provided by CSD, listed at the end of this email.
1. Deviation from Transfer Rules
Eight fields now carry a “Validation” criteria indicating that “If utility code is 1 (Included in Rent) or 2 (Submetered), populate field from “fieldname xxx” field.” This is not a validation. It is a demand for a front end process that could just as easily be met by CSD after the transfer. The database transfer rules should be exactly that - rules that validate the data received from LSPs and must be used for the independent development of local data collection systems. Since there is no validation or indication that CSD system will reject a record without the specified population, the data transferred will not be reliable.
Ron Robinette’s Response: You are correct that the record will not be rejected; however there is validation in CORE. The validation ensures that the “fieldname xxx” matches. When they do not match, CORE will populate field from “fieldname xxx” field.
Change Recommendation: This was not made clear in 3.9.2. Simply adding “CORE will populate …” In each case would suffice. DTRs address validations and not population of fields in front end systems.
2. WPO Vendor Validation
The solution reflected in the DTR for the need to collect data for federally required reports on the top WPO vendors in the state is burdensome to LSPs and will not render reliable data. No basic validation of a WPO vendor exists. The system will accept any account number for any WPO vendor for any applicant. The record for an applicant in San Diego County receiving propane from AmeriGas could reflect that the vendor was “Siskiyou Garden Apartments” or “Leo S Jones” as readily as it could “Propane Utility”.
Ron Robinette’s response: This is not new. The top 20 Propane and Oil vendors are validated against a list of vendors provided by the LSP community. After a year of collecting data we can look at whether it would be beneficial to further validate account number for greater accuracy. Other than the reporting of company name, we are not requiring any changes from our vendors at this time but feel free to raise any concerns with the Energy Division if you believe a new way to validate is needed.
Change Recommendation: This is a complete waste of staff time that front end systems may not mitigate. There is complete agreement that there is no way to assure any integrity in this data and that it is only a burden on the LSPs, yet it is still part of DTRs. In February ServTraq staff made a recommendation to collect a “Top 20 WPO” report from LSPs from front end payment records rather than place the burden of double entry on LSPs. Our recommendation still stands as it would adequately fulfills the new federal reporting requirement with the least impact on LSPs.
DTR Drafts and Documents
Utility Assistance Data Transfer Rules (DTR) version 3.9.2 with markups: http://providers.csd.ca.gov/Portals/0/documents/CORE/Data%20Transfer%20Rules/3.9.2%20UA%20Data%20Transfer%20Business%20Rules%20PY16_MARKUP.docx
Utility Assistance Data Transfer Rules (DTR) version 3.9.2 clean version: http://providers.csd.ca.gov/Portals/0/documents/CORE/Data%20Transfer%20Rules/3.9.2%20UA%20Data%20Transfer%20Business%20Rules%20PY16_ChangesAccepted.pdf
Comments can be submitted to Ron Robinette, CSD CIO, at Ron.Robinette@csd.ca.gov no later than Friday, August 26th, 12 p.m.
If you have any questions, please call or e-mail Julie Garcia or Dennis Osmer