Attachment H.docx

SCEO Consumer Protection Plan energy.gov/scep

IRA SECTION 50121: Home Efficiency Rebates

IRA SECTION 50121: Home Efficiency Rebates SCEO Consumer Protection Plan July 2025

Table of Contents

Introduction The Inflation Reduction Act (IRA) of 2022 authorizes the United States Department of Energy (DOE) to carry out two Home Energy Rebate programs – the Home Efficiency Rebates (HOMES) program and the Home Electrification and Appliance Rebates (HEAR) program. South Carolina has been granted a total of $137.2 million for these programs, with $68.5 million allocated for the HEAR program.

The South Carolina Energy Office (SCEO), a division of the South Carolina Office of Regulatory Staff, was directed by the IRA to carry out these programs. The SCEO’s serves as the principal energy planning entity for the state, and encourages energy efficiency, renewable energy, and clean transportation through a variety of initiatives. HOMES and HEAR align with this mission to promote energy efficiency and provide assistance to South Carolina residents to support energy-saving improvements.

In South Carolina, the combined impact of both HOMES and HEAR will leverage energy efficiency measures to help improve residents’ lives, lower residential energy costs, reduce overall energy demand, and contribute to a more resilient energy grid. By reducing household energy expenditures, these programs will support sustainable energy practices while benefiting the state’s broader energy infrastructure.

The SCEO has established the following goals for the state’s HOMES and HEAR Programs:

(1) Provide Holistic Improvements to Residents’ Lives: Ensure education efforts, technology systems, contractor practices, program integrations, and rebate levels are designed to meet diverse needs while lowering household energy costs;

(2) Provide Statewide Program Accessibility: Encourage program participation across all regions of South Carolina through broad outreach, education, and targeted partnerships to support hard-to-reach populations;

(3) Distribute Funds Efficiently and Drive Tangible Impact: Promote program stewardship and drive impact by distributing funds efficiently, including by leveraging household and building-wide categorical eligibility; and

(4) Leverage Existing Infrastructure and Partnerships: Build upon existing energy efficiency and workforce development efforts, integrating them with utility and other statewide programs to maximize energy savings and support long-term reductions in energy costs for South Carolinians.

In alignment with the total proportion of low-income households across the state, South Carolina intends to allocate at least 39.9% of its rebate funds to the state’s low-income households (those with less than 80% of area median income (AMI)[footnoteRef:2]). Additionally, it will allocate at least 10% of the rebate funds to low-income multifamily buildings. [2: “Area median income” is the “value calculated by household size of the median income of the area in which the individual or family resides, as reported by the Department of Housing and Urban Development.” United States Department of Energy (published on October 13, 2023), Program Requirements & Application Instructions.]

SCEO will launch its HOMES and HEAR Programs in early 2026, with a targeted soft launch followed by a full statewide launch.

Consumer Feedback SCEO will provide program participants the ability to file complaints, concerns, and issues directly to the program implementer through a call center, email, and webform (online intake tool). Consumers can ask general questions about the state program or issue a complaint regarding program services by sending an email to rebates@ors.sc.gov or by calling 803-737-0800. When a consumer reports an issue, a staff member will reach out within two (2) business days and explain how the feedback will be addressed, including the processes detailed in the “Resolution Procedures” section and the following timeline:

· If a complaint is resolved within 24 hours, the program implementer will inform the consumer via email or phone.

· If the complaint requires longer than 24 hours to resolve, the program implementer will communicate additional details to the consumer via email or phone on a regular cadence (weekly or monthly as needed) throughout the resolution process.

Beyond the listed timeline, it will also be communicated to the consumer that they can email or call to follow up on the complaint at any time, if the issue becomes urgent.

All consumer feedback reporting mechanisms, documents, and other communications will meet American with Disabilities Act (ADA) accessibility standards and the needs of non-English language speakers, including translation services in Spanish, which will be provided through the call center. Consumers can also request hard copies of online documents. More information about the program as well as this plan is found here: https://energy.sc.gov/rebates A call center will be established and managed by the program implementer on behalf of the SCEO to support applicants and contractors. Communications with SCEO’s call center will be captured via a webform or logged into the state’s application management portal by a customer service representative. This process will capture relevant information, including the name of the associated party, contact information, and location, as well as any submitted documentation related to the issue including photographs and PDF document uploads. The state will record calls into SCEO’s call center to capture key context regarding the customer’s concern. SCEO will store recordings for processing and ensure the information provided by the customer is available to best resolve the issue.

SCEO understands the importance of consumer feedback and will provide consumers with an option to complete a customer satisfaction survey no sooner than three (3) months post project completion. The survey will, at a minimum, ask consumers to respond to the statements listed in Appendix A. As part of the customer application process, the state will inform customers that they will receive a survey three (3) to six (6) months after project completion and ask customers how they wish to receive the survey (via an email invitation). No additional attempts for survey collection will be made after six (6) months.

All complaints should be submitted in accordance with the processes detailed in this section to ensure that the complaints are recorded in the system. South Carolina will leverage the state’s call center and the implementer’s call center to record and track consumer feedback. The reporting system will capture relevant information such as the name of the associated party, contact information, and location, as well as any submitted documentation related to the issue including photographs and PDF document uploads.

Consumer feedback and survey responses will be regularly reviewed for negative comments and addressed with the affected contractors, aggregators, eligible entity representatives, distributors, and/or retailers during virtual or in-person program meetings within the appropriate timeframe based on the predetermined priority (e.g., P1 = 1 business day, P2 = 2 business days, P3 = 5 business days). Feedback to program administrators will be shared through email communications, regularly scheduled meetings (such as weekly or biweekly check-ins), or phone calls.

The state will also review the number of open, backlogged, and closed consumer complaints received to ensure that proper measures are being taken. This review process will happen on a monthly basis.

Pending the severity and/or volume of the comments, the contractor will be placed on a performance plan or receive additional Quality Assurance (QA)/Quality Control (QC) training until their performance is satisfactory.

Consumer feedback will follow improvement processes as indicated in the “Continuous Improvement” section of this Plan to ensure feedback is incorporated into the next program rollout cycle.

Multifamily-Specific Process SCEO will provide details regarding a discrete consumer feedback process and corresponding directions for those households that reside in a multifamily building but are not direct program participants. Those non-direct participant households may have feedback related to quality assurance and should be provided with the opportunity to convey feedback.

Resolution Procedures SCEO understands that disputes between program participants and parties representing the state or affiliated with the HOMES program will arise in the process of delivering home energy rebates. SCEO will establish transparent and comprehensive issues resolution procedures to address these disputes.

SCEO will require the implementer to create a template to formally report and record conflicts or disputes between homeowners and contractors or aggregators in writing. The form will include, but not be limited to, the following:

· The identification of responsible parties, customer, or contractor name;

· A description of the incident/complaint;

· The date and project address;

· Phone number and email address;

· Steps taken to resolve the complaint;

· The resolution tactics inclusive of corrective actions taken; and

· Results and outcomes with date of resolution.

For instance, if a complaint is received through the call centers, survey, or via email regarding a contractor’s conduct, the implementer will assign it to appropriate staff member. If the complaint is of an urgent nature, the incident will be immediately escalated to the appropriate parties (such as the state implementer or SCEO). The escalation will be via email, regularly scheduled check-ins, or ad hoc meetings/phone calls for a timely response to address any identified systematic issues. For transparency, the defined conflict resolution procedure and Service Level Agreements (SLAs) must be acknowledged and agreed upon by all parties prior to commencement of engagement in the scope of work related to the conflict.

SCEO will develop and maintain a standard remediation process which can be applied to each third-party agreement. The assigned parties (program implementer or SCEO) are expected to contact the individual who filed the complaint within 1-3 business days and help resolve the issue as soon as possible. Some complaints may need additional steps, like additional calls to all involved parties or a follow-up visit to evaluate the circumstances.

The complaint could be lodged with one of the qualified contractors directly, and the contractors should attempt to resolve all complaints/incidents with the customer as soon as possible. This would be required of the contractors and agreed via the Program Application terms and conditions. In case there is no resolution of the customer complaint, the contractor will be required to inform the implementer.

SCEO will also publish the remediation process on the program website specifying the list of actions that could be taken by the customers with project deficiencies or unfair business practices.

When deficiencies are detected through the inspection process, the results will be recorded, communicated, and shared to the contractor and homeowner within two (2) business days with an action plan to remediate within seven (7) business days. Any remedial or appropriate actions taken will follow a pre-defined set of protocols as follows:

· A record of deficiency;

· An assessment of the level of severity regarding the issue related to the project inspection;

· Determination of remedial or appropriate action in accordance with the severity of deficiency by the appropriate parties (for example, the program implementer);

· Formal communication to the responsible party; and

· Fulfillment of remedial or appropriate action, including state verification of conformance to requirements.

The program implementer and/or SCEO will monitor, track, and close out to ensure that the appropriate remedial measures were taken in an expedited manner depending on the level of effort involved. For instance, if the customer requests financial compensation, the program implementer will work with the contractor to review the request and decide whether the contractor can replace the damaged or installed goods or if it is reasonable for the contractor to pay the amount. Overall, the program implementer will be responsible for ensuring the customer and contractor experience and resolving the issue in amicable manner.

SCEO will identify potential fraud risks and develop controls to mitigate and detect when risks will occur. SCEO will also establish an investigation process for potential fraud allegations against any program participant, including contractors, customers, and distributors. Part of this process is to also include the details of appropriate consequences that may include fines and removal from future eligibility to participate in the program, as well as possible criminal charges.

SCEO will design a process to record and investigate allegations of fraudulent activity by contractors, customers, or other program participants. Details of any investigations are to be maintained for use in the future as needed. If an allegation of fraud is made against a contractor, SCEO will follow its process to investigate, resolve, and as necessary assess appropriate consequences. This may be of a progressive nature if the allegations are stemming from multiple incidents, or it may result in a contractor being removed from the approved contractor list for the program. Consequences may be financial, administrative, or referral to law enforcement, depending on the nature of the issue, and may include removal from future eligibility to participate in the program. In every step of the processes, SCEO will prioritize the remedies to minimize the impact on the consumer and make a consumer whole in an expedited manner to maximize customer satisfaction.

SCEO will maintain records on QC inspections, including sampling rates, findings, corrective actions taken, and verification of conformance to requirements. These records will be retained for a period of seven (7) years in accordance with the state’s standard record retention policies.

Contracts associated with the HOMES program will not contain mandatory arbitration clauses. SCEO will ensure the inclusion of the holder-in-due-course rule in contracts associated with the HOMES program so consumer protections are not lost if the contract is assigned to a third-party creditor.

Deterrence Against Unacceptable Practices South Carolina will provide onboarding training to all contractors and vendors who are registered as qualified contractors. To become qualified contractors, the contractors and vendors will be required to agree to the Program terms and conditions as well as the Code of Conduct. During the training, the program implementer will communicate the deterrence processes listed below. These measures will be posted on the program website also.

Qualified contractors may be removed from the list for:

· Failing to adhere or comply with Program requirements, terms and conditions, participation agreement, or code of conduct;

· Failing to adhere to the conflict resolution process;

· Receiving two (2) or more customer complaints in a rolling 6-month period for the same issue and failing to take corrective action once the issue is identified; and

· Any other reason that SCEO or the program implementer deems necessary to protect the consumers.

The process of disciplinary action may include the following:

· First warning on confirmed offense will include a written warning and a notice to resolve/address the compliant.

· Second warning on the confirmed offense will include an indefinite suspension from the South Carolina HOMES program and removal from the qualified contractor list.

Data Review Data validation controls are critical to quality assurance in the HOMES program. Data submitted to the program for all projects through a contractor or program participant will be subject to a comprehensive data review. Only the program implementer and SCEO personnel trained on the program’s requirements for data review will conduct these activities. SCEO will execute an agreement with each aggregator and contractor who participates in the program requiring the aggregator or contractor to comply with the QA/QC processes detailed in this section.

SCEO will conduct data or file review of all projects that verify the following:

· Data Validation Controls: SCEO will employ extensive data validation methods including field requirements and validation logic, on its technology platforms to ensure controls such as exception handling and field processing error alerts are in place. The state will utilize an existing tool, if appropriate, or investigate new tools and software to ensure that data validation controls such as exception handling and file processing error alerts are in place. Should such tools be employed, the state will develop an exhaustive list of requirements that the tool must meet. Additionally, the state will outline business procedures to address data exceptions and train the appropriate staff for timely resolution and documentation.

· Home Assessment Data: SCEO will randomly select a statistically significant number of home assessments to conduct quarterly data audits to ensure all required data listed in Section 3.2.2 of the Home Energy Rebates Requirements and Application Instructions[footnoteRef:3] is captured. Additionally, the state will follow the standardized data specifications and guidelines within the IRA Home Energy Rebates: Data and Tools Requirements Guide for data captured within the assessment to ensure data compatibility. Home energy assessment data for large multifamily buildings will be consistent with Building Sync. [3: United States Department of Energy (published on June 17, 2024), Program Requirements & Application Instructions. ]

· Scope of Work Requirements: SCEO will develop a standardized scope of work template for implementers consistent with program requirements to ensure those requirements are met. The state will require the implementers to use this template to capture necessary information and provide guidance on program requirements. On at least an annual basis (but no sooner than after 12 months of data has been received, the state will review invoices for each participating contractor in the following manner: Review a minimum of 100 percent of the contractor’s first five (5) invoices, 50 percent of the contractor’s next ten (10) invoices, and 5% of each contractor’s invoices thereafter. This process aims to confirm the invoices are sufficiently detailed and the rebates are consistent with current program measures and equipment eligibility requirements (for example, equipment types and model numbers listed on the invoice are eligible for rebates under Home Energy Rebates programs).

· Installation Address Verification: SCEO’s preferred method of installation address validation is by geo-locational data. Locational data could additionally be captured through various means such as GPS or within photo/image locational metadata. If unavailable, the state will require additional proof of address through documentation such as utility bill submission. The state will require acknowledgement that installation was performed at the claimed installation address by the contractor via a signed and dated installation confirmation document (such as an invoice). The state plans to conduct quality assurance on 100 percent of all claims submitted for the first year. Through this quality assurance process done remotely or in person, the state will verify what equipment was installed and where it was installed.

· Income Category Verification: Program implementers will ensure the rebate amount aligns with the verified income category for low-income rebates by requiring a submittal of the proof of income for each rebate issued. The state will verify the documented proof of income by requesting updated income data from the source systems/qualifying programs for which South Carolina will offer categorical eligibility and will conduct an annual audit of associated rebate dollar allocations. South Carolina will offer categorical eligibility for households that participate in any of the following programs:

· Low Income Home Energy Assistance Program (LIHEAP)

· Medicaid

· Supplemental Nutrition Assistance Program (SNAP)

· Head Start

· Lifeline Support for Affordable Communications (Lifeline)

· Food Distribution Program on Indian Reservations (FDPIR)

· National School Lunch Program (NSLP) – Free

· Housing Improvement Program (HIP)

· Housing Opportunities for Persons with AIDS

· Supplemental Security Income (SSI)

· Weatherization Assistance Program (WAP) for households located in areas where 80% AMI is greater than 200% of the Federal Poverty Level (FPL)

· Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) for households located in areas where 80% AMI is greater than 185% of the FPL

· Verified government or non-profit program serving Asset Limited Income Constrained Employed (ALICE) persons or households

· Public Housing (housing owned and operated by Public Housing Authorities)

· Certificate Receipt: All completed projects under the HOMES program will receive a post-installation certificate from a qualified third party to confirm quality monitoring and accurate valuation of the upgrade. The program implementer will confirm consumer receipt of the certificate as specified in Section 3.2.6 of the Home Energy Rebates Requirements and Application Instructions[footnoteRef:4] by obtaining data such as email send confirmation, home/building owner signature, and/or a photographic proof of certificate displayed in the window of the building in which the work was performed. [4: United States Department of Energy (published on June 17, 2024), Program Requirements & Application Instructions.]

Additionally, to document safety and quality control for each project, SCEO will retain the following:

· Post-Installation Photos: SCEO will retain photos of rebate products post-installation. The associated EnergyGuide label for installed technologies must also be captured. The state will use PNNL Quality Install Tool to leverage metadata to verify location, date, and accuracy of the image. Program Implementers will retain photos of major upgrades for all homes for seven (7) years in accordance with standard record retention policies.

· Proof of Combustion Safety Testing: SCEO will require a qualified contractor, after testing, to sign off that the fossil fuel equipment meets the performance requirements. The program’s implementers will retain proof of combustion safety testing on fossil fuel equipment in all homes where fossil fuel systems have been impacted by the installation for seven (7) years in accordance with standard record retention policies.

· Proof of Commissioning Testing: SCEO will require submission of commissioning testing proof in all homes where HVAC systems are installed.

· For each project, the contractor or eligible entity representative (EER) must provide documented proof of testing and results signed by the homeowner or building owner as required by the program. The state will investigate commissioning systems and tools that may be utilized by participating contractors in the future. Program implementers will retain proof of commissioning testing on HVAC equipment in all homes where HVAC systems are installed for seven (7) years in accordance with standard record retention policies.

Finally, to document quality control for each contractor, SCEO will do the following:

· Require the third-party contractor responsible for the onsite QC on the first assessment completed by each newly onboarded contractor to provide their findings within thirty (30) days of assessment. SCEO will maintain record of QC inspections including sampling rates, findings, corrective actions taken, and verification of conformance to requirements for seven (7) years in accordance with standard record retention policies.

Conduct the data/file review monthly on 100% of rebated projects inclusive of do-it-yourself (DIY) projects that involve purchases at retailers. In the event there is an anomaly, discrepancy or exception in the data that indicates potential fraud, waste, or abuse, the state will follow data validation processes and procedures to investigate. Post install onsite inspections may be warranted and further actions may be taken to rectify the issue.

A role will be assigned and will take the responsibility of conducting the data/file review. Qualifications for the person(s) that will be tasked with such responsibilities will be as follows: bachelor's degree or equivalent experience, the Home Energy Professional (HEP) Quality Control Inspector certification, and completion of identified yearly compliance training.

All records retained by SCEO in accordance with this section will be made available to DOE upon request.

Onsite and Virtual Inspections As part of the HOMES program, SCEO has outlined the following requirements related to home inspections for projects that received a home assessment.

Inspection Approach SCEO will implement routine onsite inspections to ensure compliance with requirements for post-installation inspection. SCEO may implement virtual inspections for specified contractors based on inspection measures and job completion rates. If SCEO implements virtual inspections and a program participant declines a virtual recording of their home, SCEO will require completion of an onsite inspection.

Inspector Qualifications SCEO will work with a third-party such as local building inspectors to conduct independent onsite post-installation inspections. The selected third party must meet the minimum standard accredited certifications of BPI-Certified Quality Control Inspector or Certified Building Safety Inspector to ensure adherence to the appropriate federal and state home/building regulations.

Inspection Protocols SCEO will define and document a process for coordination of inspections with the third-party inspection entity and relevant contractors. The third party must inspect at least the first five projects completed by new contractors or organizations. Additional ongoing inspections may be required from the contractor above the minimum requirement. The inspections must be conducted within thirty (30) days of the installation. The inspection will be coordinated with the home/building owner/manager to avoid inconvenience.

To avoid any incidents of fraud, the state will require inspection of at least five (5) percent of projects for each contractor after the initial five (5) inspections are completed. The state will also keep records of the projects inspected, which must include related documentation and pictures or videos.

Failed onsite and virtual inspections must be reported to contractors and program implementers. Contractors must fix the issues found within thirty (30) days or submit an extension request for approval with the implementer. The contractor must demonstrate to both the program implementer and homeowner a feasible plan to fix the issues. A second inspection will be required after the issue has been remedied. The issue must be fixed at no additional cost to the home/building owner, but the contractor may submit a case for approval to the program implementer to request additional funds as applicable.

Onsite Inspections Onsite inspection procedures will be developed in accordance with state, county, and town building inspection agencies and will include the following procedures at a minimum. Multifamily buildings will require onsite inspections only.

· A thorough visual assessment of the site and work conditions to ensure compliance with program standards and safety protocols. This includes:

· Checking for any visible defects, damage, or irregularities that could affect energy efficiency or safety;

· Assessing the quality of installation work, ensuring proper placement and alignment of materials;

· Verifying adherence to safety protocols, including the use of PPE and compliance with building codes;

· Inspecting installed equipment to ensure proper operation; and

· Reviewing contracts, permits, and installation records to confirm alignment with the contracted scope of work.

· Inspection documentation as required for proof in the “Data Review” section of this Plan.

· Verification that the installed measures and upgrades align with the contracted scope of work, with any modifications duly documented through change orders.

· Validation of the diagnostic test results for accuracy, either through direct observation during testing or by repeating tests under the inspector's supervision.

· Compliance with E-Sign or prohibit use of electronic devices and signatures to enter into the contract if not E-Sign compliant.

Virtual Inspections In some cases, SCEO may elect to conduct a virtual post-install inspection and will partner with a third party to conduct such inspections. SCEO will implement virtual inspection protocols that shall include the following:

· A description of the methods used (e.g., video recording, interview with the site contact, photos taken during the virtual tour);

· A description of how installed equipment will be assessed;

· A list of the additional information required, such as submitted project documentation (invoices, specification sheets, and calculation models);

· Requirements for qualifying virtual inspectors;

· The tools and platform that will be used for the virtual inspection; and

· A description of privacy agreements.

Any allegations of fraudulent activity from a virtual inspection are to be dealt with in the same manner as for the process for onsite inspections. Failed onsite and virtual inspections will be reported to contractors and program implementers. Contractors will be required to remedy the issues found within 30 days at no additional cost to the home/building owner (consumer). The remedied install will then require another inspection.

Multifamily-Specific Requirement or Process The state will provide instructions for virtual inspections processes for homeowner consumers, or multifamily building owners, as this will impact the way inspections and virtual inspections are carried out.

Contractors and Other Partners In the development of a qualified contractor list within this Plan, SCEO plans to protect consumers by developing and managing through a robust development, review, maintenance, and fraud prevention process.

Contractor List Development SCEO will partner with electric and gas utilities and sanctioned state agencies to develop a qualified contractor list. Contractors for the program may include, but are not limited to, energy auditors, BPI-certified professionals, licensed electrical professionals, licensed HVAC professionals, appliance vendors, consultants, service providers, and inspectors. SCEO understands that these entities may have developed comprehensive vetting processes to ensure contractors are highly qualified, hold active certifications and offer consumers reputable services. All contractors must meet licensing, insurance, and labor standards to qualify for program enrollment.

Contractor Qualifications All contractors interested in participating in the program must complete an online contractor application. Interested contractors must also submit all information according to the guidelines set by the program implementer, which may include, but is not limited to, the following items:

· Company Name and Address

· Primary Contact Name, Email, and Phone Number

· Unique Entity Identifier (UEI)

· Licensing/Certification Information with documentation and expiration dates, such as the following:

· Building Performance Institute (BPI) Certificates

· Certified Energy Manager (CEM)

· Licensed Professional Architect

· Professional Engineer

· Proof of Insurance

· Business License

· Applicable South Carolina Contractor’s license

· Employee background checks – for ALL employees entering homes

· W-9 submission – signed and dated

· Signed Terms and Conditions Contractors must also keep their licenses, certifications, and necessary insurance(s) up to date.

· The program will track license and credential expiration date(s).

· Contractors must upload current copies of required documentation to the program implementer.

· Account managers will follow up if the appropriate paperwork is not received prior to the expiration date.

· If licenses or certifications lapse for 90 days or longer, the contractor will be removed from the participating contractor list. Future return will be evaluated on a case-by-case basis.

As SCEO implements IRA 50123 – the State-Based Home Energy Efficiency Contractor Training Grant Program (otherwise known as the Training for Residential Energy Contractors, or TREC, Program), SCEO will work with program implementation teams to review and include contractors for consideration who are trained under that program. In the event the TREC program is discontinued or changed, SCEO plans to explore alternative ways of coordinating with program implementation teams to manage a contractor network.

Contractor Review and Fraud Prevention Contractor open enrollment and review of contractor applications may occur on a rolling basis. When an application is submitted, the program implementer will perform due diligence on the contractor or distributor entity that will be on their qualified contractor lists to prevent the listing of fraudulent or illegitimate entities. This may include investigating consumer complaints, checking against databases such as the “Do Not Pay” list, or matching the business credential against state business entity lists or other available public records to ensure that the business addresses are legitimate.

All required information requested with the application must be submitted according to guidelines set by the program implementer. If there is missing information, the program implementer may deny participation in the program and provide feedback for re-submission where applicable.

Contractor Onboarding Once the application and required documents have been reviewed for eligibility, contractors that meet the program requirements will be approved and published to the contractor list.

Upon acceptance into the program, contractor onboarding activities may include, but are not limited to, receiving a welcome email, reviewing enrollment instructions and requirements for training, and assignment of a point of contact. Onboarding training may leverage a train-the-trainer or virtual model for providing guidance on program protocols, customer service, BPI Standard Procedures, and other topics.

Contractor Delisting Contractors who no longer meet the minimum requirements and standards in accordance with the associated programs will be delisted. This includes contractors who have received complaints and/or negative feedback listed in Consumer Feedback and/or failed to comply with program requirements. It may also include instances where the contractor is found to have committed some type of fraud against the program. The contractor will be removed from all associated listings on all digital channels and printed material. The contractor will also no longer be allowed to promote the ability to contract work on behalf of the program. SCEO will notify and work with the DOE Office of Inspector General on cases as needed.

Publication of the Contractor List The qualified contractor list will be publicly available on SCEO’s website (https://energy.sc.gov/rebates) (). The list will include a description of how consumers applying for rebates can use the list to access a qualified contractor. SCEO, any utility, or any program implementer is not to recommend any specific contractor to a customer or via any marketing material. SCEO will also provide consumers with a call center to address inquiries related to the qualified contractor list. It will also provide a hard copy of this information upon request.

Energy Savings Calculation SCEO will require a detailed home assessment, defined as any home assessment that meets DOE requirements outlined in Appendix B and Appendix C of the consumer protection plan guidance, to be performed and captured in an initial report before installation. The report must be reviewed and signed by the customer to ensure the findings are clearly communicated. The assessment may include the age of the property, construction type, insulation and sealing levels, and foundation condition. In addition to an initial assessment, SCEO will require a record of one year's past utility data.[footnoteRef:5] [5: Per DOE guidance, in limited circumstances where a customer is renting at the property for less than one year, states may calculate modeled energy savings through ex-ante estimates with a realization rate factor applied to align results with BPI-2400 at the portfolio level, or leveraging a DOE-approved simplified modeling approach that uses representative climate zone, weather, home characteristics, and actual average energy usage data and applies a realization rate factor to align results with BPI-2400 at the portfolio level.]

After the initial assessment and utility data are shared, the program implementer will calculate energy savings using a DOE approved and BPI-compliant software.

The definition of all measures will be described for contractors. SCEO will alert contractors to these tools and train them on proper use by hosting in-person events, webinar and/or video style training series. Additional training may be offered or required as needed.

Prioritization of Envelope Improvements SCEO and its program implementer will educate contractors and building owners on the advantages of investing in envelope improvements. Materials and communications may reference the DOE Better Buildings Solution Center and will be included as content and activities within the HOMES program’s Education and Outreach Plan.

Distributor and Retailer List Development The program implementers will partner with the federal ENERGY STAR program to develop a list of qualified distributors and retailers of energy savings products and services. It is understood that these distributors and retailers have been properly vetted and meet licensing, insurance, and labor standards to qualify for program inclusion.

The distributors and retailers on the list will have the capability with their business systems to provide instant rebates to customers at the point-of-sale, in accordance with the rules and incentive amounts affiliated with the program. The approved retailer, distributor and contractor lists will serve as resource and not a recommendation or to advocate for a specific firm, service provider or business entity.

Distributor and Retailer Reporting The distributors and retailers will report on rebates issued on a monthly basis to ensure program integrity measures are met and the DOE Rebate Tracking System is updated accurately.

The program implementers will coordinate with the state to perform marketing and store operations quality reviews to ensure that processes are being executed in accordance with established rules and directives of the program. The program implementers will also work with the distributors and retailers to proactively counter any instances or discourage incidents of fraud, waste, and abuse. If a distributor or retailer is found to have engaged in such activity, that firm will be subject to being delisted from the program along with other possible consequences.

Installation SCEO outlined requirements concerning installations, specifically installation standards with which installers must comply, as well as disclosure and payment standards if financing is involved.

Installation Protocols SCEO will require program implementers to work with building inspectors to ensure installation compliance with local and state laws, permits, codes, and industry standards. Installers must obtain the appropriate permits as applicable. Compliance will be enforced through post-installation inspections as described in “Onsite Inspections” section of this Plan.

SCEO will ensure the compliance with all applicable laws, ordinances, regulations, and codes as part of the terms and conditions in the application to become qualified contractor with the state. SCEO’s program implementer will also issue guidance and direction to contractors on proper design, installation, and testing of the equipment per project type. The guidance will provide information and resources for installers and consumers to ensure product-level minimum quality installation standards. These resources may include:

· ANSI

· ISO

· OSHA

· ENERGY STAR®

The contractors will be trained on these requirements, and the guidance will be posted on SCEO’s program website.

SCEO will instruct contractors to prioritize and integrate improvements that have the most significant impacts on reducing energy costs into their scopes of work when possible. The scope of work from the contractors will be required to provide a detailed listing of the home improvement measures, equipment specifications with energy efficiency ratings, installation, and completion approach to achieve the goal of reduced bill for the customer.

SCEO will provide consumers and installers resources to promote adherence to standardized procedures for building scope of work. These resources may include:

· Retrofit Decision Tool

· Building America Solution Center

· Energy Efficiency Hub

· Green Building Toolkit The program implementer will also follow quality assurance process that will involve sampling 5% of all home assessments for quality assurance. SCEO will also follow a similar process for on-site QC of completed jobs for onsite follow-up and verification of installed equipment:

· South Carolina will conduct on-site QC on the first five completed projects, followed by randomly sampling 25% of the next 10 completed projects.

· After the first 15 projects, South Carolina will sample at least 5% of all completed projects for quality assurance.

Equipment Upgrades For projects involving HVAC, heat pump, water heater, and other equipment upgrades, contractors will be required to properly size, install, test, and commission the equipment per manufacturer’s installation instructions. The compliance of this will be verified during the post installation inspection with diagnostic and safety testing to ensure optimal operations of the installed equipment.

Contractors, installers, and post installation inspectors shall provide evidence of the following to verify proper installation and operation of the installed equipment:

a) Equipment performance information;

b) Written job documentation or checklist inclusive of applicable testing results for the installation or procedures approved by the building inspector (for example, for HVAC upgrades, applicable testing may include airflow, electrical requirements, combustion testing and proper functioning of system controls); and

c) Geo-tagged photos of the installed equipment.

The documentation will be required to release the funds for the rebated measures. Furthermore, the contractor will be required to educate the homeowners about proper operations and maintenance. All supporting documentation should be provided to customers, such as the owner’s manual, warranty and service agreements, maintenance plans, and recommended system settings, to ensure optimal proper functioning of the installed equipment.

Installation Contracts The state or its program implementer reserves the right to provide a contract template for contractors to use. If this standard protocol is implemented, installers and contractors will be required to provide program implementers with their standard contract agreements for review if they do not use the contract template provided by the state to ensure sales and contract language are the same.

Continuous Improvement To support continuous improvement of the HOMES program, SCEO will regularly monitor and report on key performance indicators (KPIs) and provide actionable feedback. SCEO will develop a plan to mitigate fraud through assessing risks and developing controls to provide consumer protection and safeguard program funds. SCEO will take steps to identify, mitigate, and reduce fraud, waste, or abuse and unfair business practices by developing a series of manual and automated controls. Once identified, SCEO will review and resolve potential red flags prior to processing the application further. To aid in the process, SCEO may leverage data collected by the Rebate Processing Platform to inform the control design and manage potentially suspicious applications. Examples of such data are listed below:

· Duplicate IP addresses

· Duplicate property addresses

· Duplicate email addresses

· Contractor business address verification

· Installation photo geo-code matching

· Suspicious attachments

· Submission times Additional items will be identified through SCEO’s QA procedures to ensure our approach is responsive to the program's operations.

Unfair Business Practices SCEO will implement a system for preventing unfair business practices and avoiding or addressing poor program function that does not optimize a consumer’s experience by:

· Proactive prevention of and identification of fraud, waste, or abuse:

· The state will follow the guidelines within the IRA Home Energy Rebates: Data & Tools Requirements Guide to collect the appropriate data, such as the utility account number, to ensure compliance with established limitations on the rebate allowance per consumer.

· The implementer will be required to use the DOE Rebate Tracking System to ensure effective issuance of rebates, eliminate or dramatically reduce the possibility of duplicating rebates, and allow effective flow of information to the users as well as to South Carolina, the state’s implementer, and DOE.

· The state will ensure third party entities, vendors (such as software vendors), and contractors meet the specified qualifications in accordance with the work they will perform. Third parties and contractors will be required to submit a plan for responding to incidents, which will include investigating the cause and scope of the breach, securing data, and possibly issuing certain notifications of affected persons, government officials, and others. Third parties and contractors will also be required to provide Proof of substantial Cyber Security Insurance and Liability Insurance. Additional considerations will be given to B-Corp accredited entities.

· The state will provide a call center and contact form for consumers to report instances of suspected fraud, waste, or abuse anonymously. The call center and contact form will be made available to meet accessibility standards as well as the needs of non-English language speakers.

· The state plans to partner with the South Carolina Office of Inspector General (OIG), with an existing fraud hotline (1-855-SC-FRAUD or 1-855-723-7283) to report “fraud, waste, abuse, mismanagement, misconduct, violations of state or federal law and wrongdoing in the Executive Branch.” South Carolina OIG also deploys an online form to report a complaint (https://oig.sc.gov/sc-state-inspector-general-online-complaint). Like other South Carolina state agencies, SCEO will work with the South Carolina OIG to understand methods available to report cases of possible fraud.

· The South Carolina Office of Inspector General (OIG) does not have specific time limits for responding to complaints. The length of an investigation can varies greatly depending on the complexity of the case and the resources available. While there are no internal time limits, the OIG does have a process for handling complaints, as outlined on their website.

Leveraging Automation

· Program implementers will leverage web-accessible intake systems for participants, contractors, and program staff that include, where applicable:

· Required fields with datatype validation

· Application Programming Interface (API) validation to back-end, internal systems, including customer databases, AHRI and EnergyStar databases, and savings/incentive calculation engines

· Secure document intake and storage

· Ingestion and parsing of HPXML (modeling) files

· Automated verification of some aspects of modeling files, including applicable measures and usage data assumptions

· Calculation of incentives and savings, including caps and tiers for income levels

· Workflow management automation to ensure the appropriate resource reviews data at the appropriate time

· Software will connect to PNNL’s API at all required checkpoints, including during customer address AMI verification, rebate reservation, and rebate redemption. SCEO will leverage a business intelligence reporting application to analyze key datapoints gathered throughout the application lifecycle.