De-appointed Supplier Agents
This guidance provides information on the ongoing data quality obligations on Non Half Hourly Data Collectors (NHHDC) and Non Half Hourly Meter Operator Agents (NHH MOA) following de-appointment by the Supplier.
What period is a NHH MOA responsible for?
Like all agents, with the exception of the NHHDC, the NHH MOA is responsible for all Settlement Days for which it has been appointed by the Supplier in the Supplier Meter Registration Service (SMRS). This is sometimes referred to as a ‘Settlement Day Appointment’.
What period is a NHHDC responsible for?
The NHHDC is responsible for all Settlement Days for which it has been appointed by the Supplier in the SMRS, but this responsibility is passed to the new NHHDC on change of NHHDC within a Supplier registration (unless there is a change of Measurement Class from Non Half Hourly to Half Hourly). This is sometime referred to as a ‘Calendar Day Appointment’. The latest NHHDC appointed within a Supplier registration assumes responsibility back to the Supply Start Date for that Registration.
Which responsibilities endure after a Supplier Agent has been de-appointed?
Supplier Agents must retain data and provide it to their Supplier on request, for a period of 40 months after the last day of their appointment. This applies to de-appointed NHHDCs, in the same way as other Supplier Agents, despite their ‘Calendar Day Appointment’.
In addition, there is a requirement on a de-appointed NHHDC to resolve any outstanding Failed Instruction (D0023) flows sent by the Non Half Hourly Data Aggregator (NHHDA), where required to do so by the Supplier.
What are the responsibilities of the old Agent in relation to the new Agent?
What support can a de-appointed agent be reasonably expected to provide?
The outgoing agent is required to provide the incoming agent with sufficient data to allow the new agent to fulfil its obligations. This requirement survives the de-appointment of the outgoing agent. If the old agent hasn’t sent the Meter Technical Details (MTD) or reading and Estimated Annual Consumption (EAC) / Annualised Advance (AA) history, the requirement to do so endures until such time as they have done so. In the event that the old agent has no data to send, it is good practice for the old agent to communicate this to the new agent.
Should a de-appointed agent be expected to re-send or re-format data?
If the format of the data sent to the new agent doesn’t comply with the rules set out in the BSCPs or the Data Transfer Catalogue, it is reasonable for the new agent to expect the old agent to send a corrected flow. However, if the new agent has rejected the dataflow(s) for reasons that are not set out in industry governance, then any re-send is at the discretion of the de-appointed agent. If the old agent has already sent a flow and the new agent asks for it to be resent, good practice would be to re-send it (subject to low volumes of such requests).
Should a de-appointed agent be expected to carry out a site visit?
No. If you can only obtain accurate MTD by means of a site visit, it is reasonable to expect the new agent to carry out the visit. Similarly, it should be the new NHHDC that takes any actual Meter readings.
What should the de-appointed agent do if they discover an error in their own data?
If a de-appointed agent discovers an error in data that they have already sent to the incoming agent, they should send revised data. In the event that their de-appointment was concurrent with a Change of Supplier, and the error affects the Change of Supplier reading, the de-appointed agent should contact their Supplier. The de-appointed agent only needs to send revised data to the new agent, if the Change of Supplier reading has been disputed and the two Suppliers have agreed that a revised Change of Supplier reading requires amended MTD or readings to be sent to the new Supplier’s agent(s).
What should the new NHHDC do if they discover an error in the de-appointed NHHDC’s data?
A new NHHDC can amend data that relates to the previous NHHDC’s period of appointment, within the current Supplier’s period of registration. Any change to data within an earlier Supplier’s period of registration can only be effected via the disputed Change of Supplier reading process.
What happens if there has been a change of Meter?
On change of NHHDC, the old NHHDC is only required to send a reading history in respect of the latest Meter. The new NHHDC will only receive MTD relating to the latest Meter, so will be unable to process readings for older Meters. A problem can arise where the new NHHDC is required to reprocess data from the old NHHDC’s period of appointment (for example, to process revised Change of Supplier readings, following a dispute) and a change of Meter occurred within the old NHHDC’s period of appointment. The old NHHDC can resolve this problem, as they will have the necessary MTD and will know who the old Supplier’s NHHDC was, but they are no longer appointed. Alternatively, the new NHHDC can resolve the problem. They are still appointed, but will need the MTD and reading history for the old Meter. They would need to obtain these from the Supplier or the old NHHDC and MOA. Both workarounds are valid and the new Supplier is best placed to agree an approach with either the new or old NHHDC.
What should the new NHH MOA do if they discover an error in the de-appointed MOA’s data?
If the new MOA has established, beyond reasonable doubt, that there is an error in the MTD received from the old MOA, they should, as a minimum, correct the data within their own appointment.
If the error is likely to have had a material impact on readings during the period between the Supply Start Date and their appointment date, they should provide details and evidence to the old MOA and ask them to send a corrected set of MTD. If the old MOA is happy with the revised details and evidence, they should send a corrected set of MTD. Otherwise they should refer the matter to the Supplier. It is preferable for the old MOA to correct the MTD and re-send, rather than the two MOAs to make the change independently and risk further discrepancies.
If the error is likely to have had a material impact on the latest Change of Supplier reading(s), the MOA should notify the Supplier.
How should corrections be communicated?
There may be constraints in the design of some agent systems that prevent them from sending (or receiving) flows over the Data Transfer Network outside the effective dates of their appointment. Where this is the case, the old and new agents will need to agree a suitable alternative method of communication.
How should an incoming agent communicate with the previous Supplier’s agent(s)?
On concurrent change of agent and Supplier, the new Supplier’s agent will be notified of who the old Supplier’s agents were at the time of the change. If there is another change of agent (within the new Supplier’s period of registration), the new agent will be informed of the current Supplier’s previous agent. But the new agent will not be aware of the previous Supplier’s final agent(s). When a new agent needs to communicate with the previous Supplier’s final agent, they should ask the new Supplier who to contact.
How should an issue be resolved where old and new agents are unable to agree a solution?
Where the issue arises within a Supplier Registration, the current Supplier should resolve the dispute. Where the issue impacts the current Supplier’s opening read, the new Supplier should resolve the issue using the process for disputed Change of Supplier reads.
Is there a ‘cut-off point’ after which queries cannot be raised with the old agent?
Normal Settlement timescales apply. Suppliers and their agents should seek to correct any Settlement errors by the Reconciliation Final (RF) Run (or by the Disputes Final (DF) Run, if the error is the subject of an authorised Trading Dispute.
Where there have been multiple Supplier Registrations and/or agent appointments over the period of the error, the costs of correcting the error over a chain of events may outweigh the benefits of retrospective correction. In such cases, the latest Supplier and their agents should give priority to ensuring that the latest data is correct.
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