May 7, 2023 8:51 pm

It’s hard to ask for help. Utilities should make it easier.

Paperwork can be burdensome

Water and sewer affordability is a complicated challenge that demands a multifaceted solution; to meet that challenge, I’ve developed five pillars of affordability that offer utility leaders a practical way to think about affordability comprehensively and strategically. Previous posts described the first three pillars of affordability—quality, efficiency, and rate design.

This post completes the fourth pillar of affordability: income-qualified Customer Assistance Programs (CAPs). Previous posts about this fourth pillar discussed the value of simplicity in CAP design, how much assistance to offer, and why it’s important to keep administrative costs low. Today I turn from the utilities that provide CAPs to the customers who participate in them—or don’t.

Participant burdens

Designing a CAP is easy. Administering a CAP is hard. Participating in a CAP can be even harder. Every CAP imposes learning, compliance, and psychological costs on its potential participants; utilities can make each of these burdens heavier or lighter.*

Learning burdens

Learning burdens include the time and effort people expend to learn about a CAP, evaluate their eligibility status, and determine whether or how to participate. Learning is never costless, but utilities can make it easier or harder. Unfortunately, many utilities bury information about their CAPs on obscure websites or rely solely on bill stuffers to publicize their programs. Program descriptions sometimes are complicated and intimidating for people with limited English language acumen. Customers have to wade through an alphabet soup of programs and applications to find the right opportunities.

Simple benefits and eligibility rules minimize CAP learning burdens; complicated CAPs raise learning burdens. Some CAPs offer simple dollar or fixed percentage discounts, making it easy for customers to evaluate their own eligibility and potential benefit levels. Other CAPs have complicated sliding scales that apply differently for different customers depending on their incomes, household sizes, ages, and/or disability or veteran status.

Utilities can lighten learning burdens by publicizing their CAPs widely.  It’s hard to identify best practices for CAP outreach with any great confidence, since there has been little to no rigorous research on the topic. I recently conducted a large-scale randomized controlled experiment on CAP advertising using direct mail, and I’ll blog about that effort in the near future. The point here is that participation burdens starts with the cost of learning about yet another assistance program.

Compliance burdens

Compliance burdens include the procedural, informational, and financial costs that participants must bear in order to receive CAP benefits. All eligibility forms create burdens to some degree.

Some CAPs have detailed and rigorous qualification processes that require customers to provide extensive proof of income, household composition, and household expenses. CAPs that target senior, disabled, veteran, or other special populations carry additional requirements. CAPs sometimes require participants to install high-efficiency fixtures before receiving benefits. I’ve even seen water/sewer CAPs that require customers to attend an in-person interview in order to qualify—an astonishingly high barrier to participation, especially in suburban or rural areas.

Does your CAP application form evoke terrifying visions of bureaucratic overlords like this nightmarish AI-generated image?

Then after all that, participants must re-certify their eligibility periodically. It should come as no surprise that attrition in utility CAPs is often quite high.

To minimize compliance burdens, utilities that offer CAPs should make applications available in multiple formats, in multiple media and in multiple languages. Mobile-friendly online forms are good for low-income customers who may not have computers and home Internet service. But there is good evidence that many eligible people prefer hard copy, paper-and-pencil forms. Utilities should minimize required documentation of income and information about who lives “behind the meter.” Required in-person interviews should be eliminated.

A great way to minimize compliance burdens is to grant eligibility to anyone who already participates in other state or federal income-qualified assistance programs (e.g., LIHEAP, SNAP, TANF, SSI, WIC).† There’s no need to make people fill out more forms with more requirements to access yet another assistance program. Unfortunately, the state agencies that administer those other programs are seldom willing to share enrollment information with utilities owing to concerns about privacy and data security. Still, it’s an avenue worth pursuing whenever and wherever possible.

Psychological burdens

A host of indignities accompany benefits under most income-qualified programs. The very act of applying for help in paying for an essential service like water carries a social stigma in a country that proudly values individual responsibility. Decades of research on income-qualified programs show that extensive, repeated documentation and administrative supervision cause uncertainty and frustration with seemingly endless red tape and approval procedures. Beyond the cognitive stress that administrative processes create, CAPs erode individuals’ sense of autonomy and self-worth with every required document and procedural hurdle.

CAPs that minimize learning and compliance burdens also minimize psychological burdens. From outreach to intake to benefits administration, utilities can reduce the psychological burdens with careful choices of language and imagery that minimize social stigma.

So. Much. Documentation.

Words like “hardship” and “forgiveness” imply that assistance is for people of low social and/or economic status. To ask for assistance is to declare oneself weak, irresponsible, or in need of forgiveness. San Antionio’s UpLift is a good example of how to reduce those psychological costs when communicating about a about CAP: the program's name and associated imagery seek to maintain the participant's dignity.

Lightening the load

There’s a deep and too-little recognized tension between the “human right to water” language that pervades discussions of affordability and the calls for CAPs that usually follow. The rhetoric of rights implies an affirmative responsibility of the state to provide people with basic water/sewer services at affordable prices. The reality of CAPs is that assistance flows to people who demonstrate to authorities that they deserve help. You don’t actually have the right to something if you have to come to the government, hat in hand, to ask for that thing.

If the point of a CAP is to help people afford water/sewer bills, then minimizing participatory burdens is critical to success. Here again, simplicity is a great virtue. CAPs with clear benefits and straightforward eligibility rules keep learning, compliance, and psychological burdens low; CAPs with complicated benefit and eligibility schemes increase burdens.

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So long as water systems operate on a fee-for-service basis, some customers will struggle to pay their bills—even when utilities provide high-quality service, operate efficiently, and price progressively, and offer simple and effective CAPs. Any organization that bills customers will eventually have to deal with delinquencies; managing those delinquencies is the fifth and final pillar of affordability. I’ll take that up next time.




* Public management experts call these costs "administrative burdens." For the definitive work on the subject, see Pamela Herd & Donald Moynihan’s 2018 book, Administrative Burden.

†Some utilities already follow this key element of the Walden Pond Assistance Plan, which also saves them the administrative cost of collecting and maintaining extensive documentation. A few utilities even simply allow customers to self-certify their own eligibility.


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