Update: Details Of Retail Supplier's Proposed New In-Person Contactless Enrollment Process Revealed

June 1, 2020

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Reporting by Paul Ring • ring@energychoicematters.com

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A public version of a proposed new contactless enrollment process for in-person sales conducted at retail establishments (in-store sales), proposed by the NRG Energy retail suppliers in Ohio, has been filed, per prior direction of an attorney examiner

An earlier filing had sought confidential protection for much of the description of the proposed new contactless enrollment process for in-store sales.

As previously reported (see specific details here), the NRG suppliers are seeking a waiver of PUCO's order prohibiting in-person sales to allow the new contactless enrollment process for in-store sales

The full description of NRG's proposed process, which has now been publicly disclosed, is as follows:

NRG has modified its in-stores sales program with safety in high priority, as follows:

Ensuring Sales Agent and Customer Safety: All agents will be required to conduct daily temperature checks before being permitted to go into a partner’s retail location. Agents will be provided with single-use face masks, single-use disposable stylus pens, hand sanitizer and disinfectant wipes. All agents will be trained to maintain physical distancing following the Ohio requirements and the Center for Disease Control’s guidelines. Ohio’s six-foot social distancing requirement will be designated for the agents and customers. Agents shall conspicuously sanitize the sales space after each interaction with a prospective customer. Hand sanitizer and disinfectant wipes will be available for customers as well. Separate operating hours for the elderly and vulnerable customers will coincide with the retail partner’s operating hours for such customers.

Ensuring a Contactless Enrollment Process: Agents will be trained on the new "contactless" enrollment process, which entails:

• Electronic tablets will continue to be used to initiate the sale and collect required customer information (name, address, utility account number, phone number, email address) for enrollment purposes, but with only the agents maintaining possession of the tablets and entering the information provided verbally by the customer.

• The customer will provide an email address or cell phone number under this new process in order for the next step in the enrollment process to take place.

• The customer will instantly receive an email or text message with a unique hyperlink to a secure enrollment website. Using that unique hyperlink, the customer will complete the enrollment directly on his or her personal device.

• The agents will be trained to assist the customer verbally as needed.

• The customer will review the Terms of Service and check the appropriate boxes to attest they are authorized to enroll, are over 18, accept the terms of the supply plan selected, and that they understand they are enrolling. The customer will sign the enrollment form on their own device with his or her finger or one of NRG’s disposable stylus pens.

• The customer must hit the Submit button on the screen of his/her phone to complete the enrollment.

• Once submitted, a welcome email, contract summary and Terms of Service will be emailed directly to the customer, or if the customer chose not to provide an email address, the materials will be delivered via U.S. mail. The customer will also be able to pick up a paper copy of the contract summary and terms of service.

• Enrollments that are not completed by the customer at the point of sale will not be processed. (In such cases, the customer has provided consent but is unable at the point of sale to provide a necessary piece of information - typically the utility account number. NRG may follow up on partial enrollments through email, phone or text to obtain the incomplete information. If NRG is unable to get the information, the enrollment is not processed.)

Case 20-1008-GE-WVR

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