Payment difficulties and hardship – energy retail
January 2016
Background
EWOV receives and investigates complaints about financial hardship, sometimes where customers are
unable to pay for their ongoing energy usage and/or arrears. Often customers contacting EWOV with
affordability issues have accrued considerable debt and have had, or are at risk of having, their
electricity and/or gas supply disconnected. This statement outlines EWOV’s view of what is fair and
reasonable in these situations.
Definition of financial hardship
A customer in hardship is defined as “a residential customer who has the intention but not the capacity
to make a payment within the timeframe required by the retailer’s payment terms”.1
Objectives during an EWOV investigation
When handling complaints involving financial hardship, EWOV aims to:
 achieve consistency in hardship complaint handling, including shared expectations between
EWOV, customers and providers for complaint progression and appropriate outcomes
 conduct timely investigations of hardship complaints in order to minimise accrual of customer
debt, including early identification of potential or actual hardship, monitoring payment by
customers of undisputed or affordable amounts and seeking relevant independent advice2
 promote and facilitate sustainable outcomes for customers and providers which go beyond
regulatory compliance and include principles of best practice.3
EWOV aims to repair, and where possible improve, the relationship between customers and providers
by achieving outcomes that are realistic, maintainable and reflect the customer’s capacity to pay.
Considerations during an EWOV investigation
Each complaint is reviewed on its individual merits and its outcome will depend on the circumstances of
the complaint. However, for hardship complaints EWOV will usually consider:
1. a timeline of events and the relevant facts
2. special customer circumstances
3. laws and codes
4. independent advice
5. regulatory advice
6. current good industry practice, past outcomes for similar investigations and previous Binding
Decisions
1
Clauses 3 and 71B Energy Retail Code Version 11 (Energy Retail Code), the same definition was previously contained in clause
2.2 of the Essential Services Commission’s Guideline 21 – Energy Retailers’ Financial Hardship Policies.
2
For example, a financial assessment to assist with establishing capacity to pay and affordability, or energy audit/efficiency
advice to provide understanding about consumption patterns and potential usage reduction.
3
EWOV aims to assist customers to manage and pay for their energy usage, and to assist energy retailers to identify customers
who may require assistance, as well as helping providers promote habits of sustainable payment and usage by their customers.
Achieving sustainable outcomes also enables risk mitigation relating to future energy consumption and payment, for both
customers and providers.
7. energy provider policies and their application
8. other industry practice.
1. A timeline of events and the relevant facts
For this type of complaint it is important for EWOV to establish:
 Any relevant special customer circumstances.
 The customer’s consumption and payment history, including fortnightly4 usage information.
 The amount the customer can afford to pay per fortnight.5
 The status of the account, including whether it is an active or closed account.
 The amount and age of any debt.
 Whether the customer has debt for a single fuel, or for both electricity and gas.
 Whether the customer self-identified as being in hardship or provided any information about
their capacity to pay.
 Whether the customer has complied with their regulatory obligations, such as making payments
and providing identification as required.
 Whether there were hardship indicators, and any steps taken by the provider once it became
aware of the customer’s financial circumstances.
 Whether the provider has complied with its regulatory obligations, including offering flexible
payment plans in line with a customer’s capacity to pay, or access to energy audits or appliance
replacement where appropriate.
 What genuine actions or efforts the provider has taken to engage with the customer, alert them
to the debt and advise them of available support and assistance.
 Any proof or documentation available to support the actions taken by the provider once it
became aware of the customer’s financial hardship. EWOV expects that copies of the actual
documents sent to the customer will be provided.
 Whether all applicable concessions and discounts have been applied to the account.
 Whether the customer is on the most appropriate tariff for their circumstances.
 Whether there was any dispute concerning the outstanding debt, and how it was managed or
resolved.
 What efforts the customer made to engage with the provider about the debt and their
affordability issues.
 Whether the customer has demonstrated an intention to pay and participate in a hardship
program, or otherwise engage or work towards a sustainable outcome.
 Whether the customer has sought additional assistance or support from community groups to
manage their financial commitments.
 Whether the customer or provider initiated communications.
 Whether the customer has previously participated in the provider’s hardship program, and if so,
the outcome of any past participation.
 Any other relevant information depending on the facts of an individual complaint, as the above
list is not exhaustive.
4
EWOV usually refers to a customer’s fortnightly consumption for consistency and ease of reference, however in individual
cases daily, weekly, monthly or annual consumption may be more relevant to EWOV’s investigation.
5
As with usage, EWOV usually refers to a customer’s capacity to pay on a fortnightly basis for consistency and ease of
reference, however this may vary in individual cases.
2. Special customer circumstances
EWOV considers any relevant special customer circumstances, including whether the actions or inaction
of the provider have had adverse consequences for the individual customer. In particular, EWOV
considers the following:
 The extent of financial hardship – whether it is short term or long term.
 The actions taken by the customer to engage with the provider. If the customer has previously
been offered assistance under the provider’s hardship policy, EWOV will consider whether the
customer engaged adequately in the process.
 The actions taken by the provider to engage with the customer.
 Payment history.
 Disconnection history.
 The customer’s capacity to increase payments.
 The customer’s eligibility for concessions or other assistance – for example payments under the
Utility Relief Grant Scheme (URGS).
 The customer’s capacity to reduce usage, which may be impacted by a variety of factors, such as
medical conditions which require consistent ambient temperatures, rental premises where the
customer has limited capacity to install more energy efficient appliances, and/or appliance
repairs, replacement or other works, such as insulation installation, requiring capital outlay
which may be beyond a customer’s limited resources.
 Any history of contacts to EWOV and whether circumstances have changed since the customer’s
last contact with EWOV.
 The customer’s participation in EWOV’s investigation, including making ongoing affordable
payments, participation in a financial assessment or energy audit and taking steps to reduce
usage where possible.
 Personal circumstances and available support – from community groups, family, friends.
 Whether the premises has life-support registered.
 Anything which may mean the customer is vulnerable – for example, age, education, language,
health, disability.
3. Laws and codes
EWOV expects customers and providers to meet their legal and regulatory obligations. Obligations
under laws and codes represent minimum standards. Consideration of what is fair and reasonable
includes, but is not limited to, the legal requirements. This means that, while a provider may have
complied with its regulatory obligations, EWOV’s assessment of the complaint may determine that
compliance alone is not fair and reasonable in the individual circumstances, and an alternative
resolution may be required.
The Electricity Industry Act 2000 (Electricity Industry Act), Gas Industry Act 2001 (Gas Industry Act) and
any laws, codes or guidelines made under them (for example, the Energy Retail Code)6 all place legal
obligations and responsibilities on energy retailers and customers.
Hardship policies
All energy providers must have a customer hardship policy which has been approved by the Essential
Services Commission.7 Providers need to have processes in place to identify hardship customers and to
6
This is not an exhaustive list and EWOV will consider all relevant laws and codes. The legislative and regulatory framework
relating to the energy industry has a consumer protection purpose, and EWOV interprets laws and codes to be consistent with
this purpose.
work with customers or their representatives (such as financial counsellors) to assess the appropriate
options. Energy retailers are also required to make staff aware of their hardship policy and to ensure
their staff have the necessary skills to sensitively engage with customers in hardship.8
After identifying a hardship customer, an energy provider must promptly inform that customer of its
hardship policy, advise the customer of their rights and obligations under the hardship policy and let the
customer know about the options or assistance available. Energy retailers are required to be
transparent, accessible and to communicate with hardship customers, financial counsellors and
community assistance agencies.9
Although an energy provider does not have to offer all the options available in its approved hardship
policy to an individual customer, the energy retailer must provide a hardship customer with equitable
access to appropriate options for their particular circumstances.10 Some of the options required under
energy retailer hardship policies include:
 the offer of fair and reasonable payment options including appropriate instalment intervals that
accommodate an individual customer’s particular circumstances
 monitoring of payments including the accumulation of debts
 details about how customers will be helped to maintain payment plans or other options offered
 details about the availability of, and any costs for, energy audits
 information about when and how a retailer will offer assistance to replace or repair appliances
 monitoring and recommendations regarding appropriate tariffs
 referral to support agencies and schemes where appropriate
 information setting out the circumstances when hardship arrangements or assistance may or
will end.
Payment plans
Energy providers are also required to offer a payment plan to hardship customers or any other
residential customers experiencing payment difficulties.11 A payment plan established must have regard
to the customer’s capacity to pay, arrears owed by the customer, and the customer’s expected energy
consumption for the next 12 months. In addition, where a payment plan is offered, the energy provider
must give details of:
 the duration of any plan
 the amount payable for each instalment, the frequency of instalments and the date by which
each instalment must be paid
 if the customer is in arrears, the number of instalments to pay the arrears
 if the customer is to pay in advance, the basis for calculating the instalments.12
Providers are also required to enable payment by Centrepay for hardship customers.13
7
Division 6 Electricity Industry Act, Division 4A Gas Industry Act and Clauses 71, 71A and 71B Energy Retail Code. The objectives
underpinning this requirement are recognition that residential customers may suffer from financial hardship, and promotion of
best practice for energy service delivery to facilitate continuity of electricity and gas supply for customers experiencing hardship
(Electricity Industry Act section 42, Gas Industry Act section 48F).
8
Clause 71B Energy Retail Code.
9
Clause 71B Energy Retail Code.
10
Clause 71B Energy Retail Code.
11
Clause 33 Energy Retail Code.
12
Clause 72 Energy Retail Code.
13
Clause 74 Energy Retail Code.
General comments about customer engagement, hardship assistance and payment plans
When investigating a complaint, EWOV will consider whether an energy retailer acted on possible
hardship indicators, provided appropriate financial assistance and advice for the individual customer,
and/or suggested appropriate payment plans. EWOV will consider whether any offers or suggestions to
resolve a complaint are fair and reasonable in the circumstances.
EWOV expects that providers will be able to demonstrate how they have complied with their regulatory
obligations to assist customers with payment difficulties, including the offer of formal hardship
assistance where relevant and appropriate. Without documentation or substantiation, EWOV will be
unable to confirm that the provider has complied with its regulatory obligations, and this may alter what
is required to achieve a fair and reasonable outcome in the circumstances.
EWOV expects that energy retailers are able to provide actual copies of documentation sent to a
customer, or other relevant information, to demonstrate compliance with their legal obligations.14 If the
energy retailer is not able to demonstrate to how it has complied with its regulatory obligations, then
EWOV will ask the provider how it intends to address the issue in order to resolve the complaint.15
While some customers may not be eligible or suited to a provider’s formal hardship program, or
inclusion is not appropriate in the circumstances, providers are still obliged to offer a level of assistance
to all customers in hardship. Even in circumstances where it is fair and reasonable for a customer to be
denied further opportunity to access a provider’s formal hardship program, EWOV will usually expect
providers to have other options available for hardship support and assistance, rather than placing those
customers on a standard collections pathway.
EWOV considers that the legal obligation to offer support and assistance to customers in hardship or
experiencing payment difficulties, including offering affordable payment plans, continues to exist after a
customer’s account is closed.16 EWOV acknowledges that the support and assistance available to a
customer with a closed account may be more limited than what is available to customers with active
accounts. However, EWOV considers it is not appropriate to only have two options – formal hardship
assistance or a collections pathway.
EWOV’s case handling experience indicates that often when customers’ accounts are closed they lose
access to affordability support and are instead placed on a standard collections pathway. EWOV believes
this is inconsistent with an energy retailer’s regulatory obligations to offer tailored, individual solutions,
assistance and support to customers experiencing payment difficulties. Where customers remain
engaged and willing to participate, EWOV considers these obligations continue even once a customer’s
account has been closed.
Debt collection
An energy retailer cannot commence legal proceedings for debt recovery if:
 The customer continues to adhere to payment plan terms
14
Generic template documents or system generated records (for example “data successfully extracted”) are not sufficient.
For example, access to the hardship program, payment/s to acknowledge missed URGS opportunities, reduction in usage
charges to reflect lack of energy efficiency advice being provided, and/or extended payment arrangements may all be ways for
a provider to acknowledge and address regulatory non-compliance.
16
For example, if a customer moves and the account is final billed, or if they transfer to another retailer. This is because
accrued obligations survive contract termination, see clauses 49(3) and 70(5) Energy Retail Code, clause 4.2(c) Model Terms and
Conditions.
15
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The energy retailer has failed to comply with the hardship policy requirements
The energy retailer has failed to comply with laws that relate to non-payment of bills, payment
plans and assistance to customers experiencing payment difficulties, or debt collection
guidelines.17
EWOV considers that an energy retailer should not commence debt collection activity (including, but not
limited to legal proceedings) unless it has complied with all of its regulatory obligations, or in instances
where a customer is engaged and participating.
In case handling it can be difficult to identify when a payment plan has formally ended and when debt
collection can start. Before commencing debt collection, a provider should be able to establish it has
advised the customer that any payment plan has ended (usually due to the customer failing to make
payments). EWOV would expect the energy retailer to provide a copy of any such communication with
the customer.
4. Independent advice
EWOV considers any appropriate technical advice, and where relevant will arrange for financial
assessments and energy audits. EWOV works with the customer and provider towards reducing the
customer’s consumption whilst increasing their capacity to pay. This approach is aimed to minimise the
gap between the ongoing cost of supply and what the customer can afford to pay.
To ensure the achievement of a sustainable, fair and reasonable outcome, EWOV will review any
financial assessments conducted by the provider or by a qualified financial counsellor. As part of the
investigation EWOV may also conduct its own independent financial assessment and/or energy audit.
Financial assessment
EWOV does not provide financial counselling or formal financial advice, but uses information/advice
from our Financial Assessor to:
 Gain an understanding of a customer’s individual circumstances and their capacity to pay.
 Assist a customer to access all benefits, concessions, additional income or government benefits
for which they are eligible.
 Provide appropriate referrals, for example to local financial counsellors.
Energy audit
In conjunction with meter data, EWOV uses energy audit information and advice to:
 Gain an understanding of a customer’s individual circumstances and consumption.
 Work with a customer to improve their understanding of their usage patterns and general
consumption.
 Identify and explore possible opportunities to reduce usage.
 Work towards decreasing usage so that cost of supply is within the customer’s capacity to pay.
 Identify faulty or incorrectly functioning appliances, which can be addressed by:
o changing the settings on the appliance
o changing the network tariff to reflect how the appliance is used
o repairing the appliance
o replacing the appliance.
17
Clause 72A Energy Retail Code.
EWOV will review the information provided in the energy audit and/or financial assessment, provide
relevant information to the customer and provider, and work with both parties to achieve a fair and
reasonable outcome.
5. Regulatory advice
Depending on the circumstances, EWOV may seek advice from relevant regulators, such as the Essential
Services Commission (ESC), the Australian Energy Regulator (AER) or the Australian Competition and
Consumer Commission (ACCC) for an individual complaint. Recent reviews by both the AER and ESC
provide general guidance about affordability issues.
AER review
The AER has reviewed energy retailer’s hardship policies and practices and, in January 2015, reported on
its findings, including indications of best practice.18 The AER’s report suggests there are problems with
identifying and assisting customers, and the more effective approaches involve a combination of
strategies, such as:
 increasing customer awareness about how and when to seek retailer assistance
 proactive contact by retailers at first signs of payment difficulties via a range of methods
(including SMS, phone calls and email)
 approaching hardship issues with more empathy and sensitivity so that customers receive the
support and help to which they are entitled.19
The AER also highlighted the importance of assisting customers to maximise their capacity to pay, by
ensuring they have accessed all grants or concessions for which they are eligible and reducing their
energy consumption. The report noted that some retailers offered a more holistic range of assistance,
including energy efficiency audits, appliance replacement and retrofit programs, and referral
arrangements.20
The AER report is useful for EWOV because it gives guidance about regulatory interpretation and
regulator expectations in relation to affordability issues.
ESC review
The ESC is currently undertaking an extensive inquiry into and assessment of the overall operation of the
current regulatory framework in Victoria.
The ESC noted the purpose of the current Victorian regulatory framework can be defined as assisting
customers facing payment difficulties to avoid long-term debt, and repay debt that does accrue, while
wherever possible maintaining access to energy as an essential service. The ESC used this purpose as a
reference point for its inquiry.21
18
Australian Energy Regulator, Review of Energy Retailers’ Customer Hardship Policies and Practices, January 2015 (AER
Report). The review and report focused on retailers with residential customers in jurisdictions where National Energy Retail Law
and National Energy Retail Rules apply. The review and report are useful, as the obligations under version 11 of the Energy
Retail Code are similar to the obligations under the National Energy Retail Rules, and “the review offers an important
contribution to the national conversation on issues of energy affordability and hardship.” (AER Report p3)
19
AER Report p9
20
AER Report p15
21
The ESC has produced a draft report: Essential Services Commission 2015, Supporting Customers, Avoiding Labels. Energy
Hardship Inquiry Draft Report, September 2015 (ESC Report) p18. The final report is anticipated in early 2016.
The ESC’s review and report concluded that the key elements of best practice include:22
 Early identification of customers experiencing payment difficulty.
 Payment plans that customers can afford.
 Practical in-home assistance for customers with their energy management.
 Partnerships with government and the welfare sector to address the underlying causes of
payment difficulty.
 Clear and strictly enforced procedures for disconnection.
 Use of prepayment to assist customers to reduce consumption.
 Guaranteed service levels as incentives for retailers to provide assistance for customers.
The ESC review and report provides guidance about the anticipated changes to regulatory obligations as
well as outlining the ESC’s expectations in terms of assistance for customers experiencing affordability
issues. Where appropriate, EWOV will take into consideration the ESC review, report and key elements
of best practice when considering what is fair and reasonable for an individual complaint.
When assessing a fair and reasonable outcome, EWOV will also consider any relevant ESC decisions
about the application of a wrongful disconnection payment for breaches of hardship provisions of the
Energy Retail Code, particularly where those decisions provide guidance about regulatory interpretation.
6. Current good industry practice, past outcomes for similar investigations and previous Binding
Decisions
When handling complaints involving financial hardship or payment difficulties, EWOV aims to achieve
sustainable outcomes which go beyond regulatory compliance and include principles of best practice. To
be sustainable, outcomes need to be realistic, maintainable and reflect a customer’s capacity to pay.
When assessing what is fair and reasonable in an individual complaint, EWOV expects the actions of a
provider will be consistent with or exceed current good industry practice, as well as being consistent
with appropriate past complaint outcomes and previous Binding Decisions.23
EWOV’s experience in dealing with these types of complaints indicates:
 Customers are expected to participate appropriately in resolving their complaint, including
making regular payments, staying in contact and making efforts to reduce usage where possible.
Providers are also expected to participate actively to resolve complaints.
 It is vital for a provider and EWOV to consider a customer’s individual circumstances in
affordability complaints. The most effective outcomes result from tailored energy efficiency
advice and appropriate financial assessment after considering the customer’s particular
circumstances and capacity.
 It is common for EWOV’s Financial Assessor to recommend a payment arrangement that is less
than the payment plan offered by a customer’s retailer after its capacity to pay assessment,
22
ESC Report p73. Changes to the regulatory framework are expected in order to implement some of the key elements of best
practice.
23
One of EWOV’s Binding Decisions relates to disconnection of gas supply and hardship (GD/2001/13 – May 2002). In that
decision, the Ombudsman required the gas provider to waive approximately 86% of the customer’s debt (reducing the balance
from $2,741.69 to $390.00). The company was required to accept a payment of the remaining arrears over 12 months. The
Ombudsman’s decision was based on advice from the customer’s financial counsellor about the customer’s capacity to pay. If
the customer failed to make the required payments, the company was able to pursue the debt through standard collections
processes.
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which suggests retailers are not offering affordable and sustainable payment arrangements to
customers in financial hardship before they come to EWOV.24
Where retailers have not appropriately assessed a customer’s capacity to pay, or have otherwise
failed to meet regulatory obligations, it is common for customers to be provided with support
on an energy retailer’s formal hardship program, even where that customer might otherwise not
be eligible based on the energy retailer’s criteria. Other options to address regulatory noncompliance can include payments to recognise the lost opportunity to access URGS, debt waiver
or reduction to recognise failure to provide effective energy efficiency assistance or extended
payment plans.
It is not appropriate to only have two options – formal hardship assistance or a collections
pathway. Energy retailers are required to offer a level of support to customers who may
otherwise be ineligible for formal hardship programs, or for customers with closed accounts. In
most cases it will not be fair and reasonable for a customer to be automatically placed on a
standard collections pathway if that customer requires a level of support due to affordability
issues.
Energy efficiency advice is most effective as a tool when it is tailored to the customer’s
individual circumstances. Although onsite energy audits are the most effective method for
providing energy efficiency advice, EWOV also finds phone discussions can be useful when a
customer’s individual circumstances are addressed.
Appliance replacement can be a useful way to resolve complaints and help reduce usage to
meet capacity to pay.
Changes to a customer’s tariff can also be useful in reducing a customer’s bills.
There are instances where it may be fair and reasonable for the energy retailer to waive a
portion of the customer’s debt, for example if there are significant customer service issues, or
where the retailer has contributed to the debt accrual.
EWOV aims to achieve sustainable outcomes, where capacity to pay and usage are aligned,
however this is not always possible. Sometimes it is appropriate for a customer to have a period
of subsidised usage, to enable them to reduce consumption and bring cost of use in line with
affordability, or when the customer’s financial circumstances are expected to imminently
improve.
In some circumstances it may be fair and reasonable for an energy provider to offer an incentive
plan25 or a longer term/indefinite subsidised arrangement.26
7. Energy provider policies and application
EWOV acknowledges that, although the intent and regulatory requirements are the same for all energy
providers, hardship policies may differ depending on the provider’s customer base, the strategic
direction of the provider and the range of services provided.
EWOV will review the statements or representations contained in the provider’s Hardship Policy and
Customer Charter, about how the energy provider will deal with financial hardship issues.
24
Energy and Water Ombudsman (Victoria), A closer look at Affordability: An Ombudsman’s perspective on energy and water
hardship in Victoria, March 2015, p29
25
Where the energy retailer makes contributions (usually towards arrears/debt) based on a customer meeting regular, agreed
payments.
26
For example, where a customer has a medical condition which prevents them from reducing usage.
EWOV will consider the application of those policies. EWOV expects that providers will adhere to any
statements or representations made in their Policies and Charters.
8. Other industry practice
Because water providers have similar legal obligations requiring them to assist and support customers
experiencing affordability issues, advice from water providers can be useful in establishing fair and
reasonable complaint outcomes for energy complaints. In addition, information from the financial or
telecommunications sectors can also be valuable in establishing what is fair and reasonable in the
circumstances of an individual complaint. Where appropriate, EWOV will seek other industry practice
from water providers, or from other sectors.
Complaint resolution and outcomes
In relation to affordability complaints, EWOV considers that a provider should be able to demonstrate:
 Genuine consideration of the customer’s individual circumstances, including offering assistance
and support that is appropriate, relevant and tailored to address those circumstances.
 Compliance with any legal or regulatory obligations as a minimum standard.
 Timely and appropriate action to identify whether the customer is in hardship and assess the
customer’s capacity to pay.
 Appropriate action taken to minimise accrual of the customer’s debt.
 Any advice provided to the customer about the existence of the URGS and financial counselling
services.
 Any individual and tailored energy efficiency advice which has been provided to the customer.
 Efforts made to prompt the customer to engage, including any reasonable requests for
information enabling the provider to offer various options to assist the customer.
 Correct and appropriate application of the provider’s hardship policy.
 Any genuine efforts or steps taken to alert the customer to the debt, to clearly notify the
customer of the potential for supply disconnection if the debt is not managed and to advise of
the support and assistance available.
 Disconnection or other debt collection/recovery processes are undertaken as a last resort.
 Why its resolution offer is fair and reasonable in the circumstances.
To resolve these types of complaints, EWOV may:
 Ask a provider to accept the customer on to its formal hardship program and provide ongoing
support, which could include monitoring consumption and payments.
 Ask a provider to make payments to acknowledge lost opportunity or opportunities to access
URGS payments.
 Ask a provider to reduce usage charges to reflect a lack of useful energy efficiency advice.
 Ask a provider to consider offering additional assistance, such as financial contributions towards
repair or replacement of damaged appliances.
 Ask a provider to offer the customer an extended payment plan. This may be especially relevant
for customers with closed accounts, which do not have the same issues of ongoing usage and
debt accrual as active accounts. It may also be relevant if the customer has separate energy
costs for new premises or with a new retailer.
 Ask the provider to waive a portion of the debt, where the provider has contributed to debt
accrual, or where it is otherwise appropriate (for example, in recognition of customer service
issues). Failure to intervene or offer early assistance to customers (for example via energy
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audits, appliance replacement or even via disconnection) may be both a regulatory compliance
and a customer service issue.
Ask the provider to put the outstanding debt on hold, accept a payment plan that meets
ongoing consumption, and/or offer an incentivised payment plan.
Ask the provider to accept a subsidised payment plan (one that does not meet consumption)
over an agreed period of time, while the customer works to reduce their consumption so that
cost of use aligns with capacity to pay. In some exceptional circumstances it may be appropriate
for a customer to be offered an extended or indefinite subsidised payment plan, for example
where there are significant medical issues.
Ask a provider to make any appropriate additional offers to resolve the complaint, which could
include further recognition for customer service issues.
Where a customer has been previously removed from a hardship program, and is seeking financial
hardship assistance, EWOV will consider the circumstances of the individual complaint, to assess
whether completion or removal from the hardship program, and/or cancellation of a payment plan is
appropriate or fair and reasonable in the circumstances.