Auto-enrollment quadrupled participation where implemented — but only two utilities across five states have tried it
Burlington Electric Department auto-enrolled Seasonal Fuel Assistance recipients into its Energy Assistance Program. Enrollment jumped from 3% to 12% of eligible customers — a 4× increase with no additional marketing spend. Wisconsin's Energize Wisconsin pilot auto-enrolled WHEAP participants into community solar with no additional paperwork. Despite this evidence, no state requires auto-enrollment as a program design standard.
Burlington Electric: before and after auto-enrollment
Before auto-enrollment
3%
219 customers enrolled in EAP. Customer-initiated application required. 14% of BED customers received disconnection notices — enrollment was a fraction of need.
→
After auto-enrollment (2024)
12%
776 customers enrolled. Seasonal Fuel Assistance recipients auto-enrolled. Projected to reach 17% by December 2026. No additional marketing spend required.
VT PUC, Act 142 Final Report, Dec 1, 2025, pp. 29-30.
Enrollment methods spectrum: what each state uses
Auto-enrollmentData-sharing with income verification agencies
3% → 12%
CBO partnershipsCommunity-based enrollment sites
83.7%
Streamlined eligibilityNo income docs if in safety-net programs
Varies
Consent data-sharingOpt-in checkbox on LIHEAP application
6 yrs to build
Customer-initiatedCustomer must find and apply for program
4–35%
Pennsylvania's data-sharing journey: 6 years from concept to implementation
Apr 2018
LIHEAP Advisory Committee Data Sharing Subcommittee first formally meets.
2019-23
Subcommittee develops framework. Privacy concerns, IT system integration, and consent mechanisms debated across multiple utility and state agency stakeholders.
May 2024
PA PUC presents "Agency/Utility Data Sharing" framework at stakeholder meeting. Consent-based model finalized.
Nov 2024
Implementation: LIHEAP applicants can opt in (check a box) to share data with their utility for CAP/LIURP/Hardship Fund eligibility. Six years from first meeting to first checkbox.
4×
BED's enrollment increase through auto-enrollment — from 3% to 12% of eligible. The GDS Associates 2019 assessment found "even in EAPs with the highest participation rates, fewer than half of qualified customers participate."
<10%
Of Massachusetts heat pumps that went to LMI homes (2022-2024) despite $85.5K/year community partnerships, 52 Community First Partners, 21 Designated Equity Communities, and 5-language support.
2
Utilities across all 5 states that have implemented true auto-enrollment (BED for EAP, WI Energize for community solar). No state requires it. Most rely on customer-initiated processes that produce 4-35% enrollment.
The enrollment evidence across five states is clear: auto-enrollment works; everything else is a compromise. Community-based partnerships (PECO: 83.7%) work if you invest in 30 enrollment sites. Streamlined eligibility (Wisconsin) removes paperwork barriers but still requires the customer to act. Consent-based data sharing (Pennsylvania) takes six years to build and still requires the customer to check a box. Customer-initiated enrollment produces the lowest rates everywhere it's measured — and it's the default in most programs.
The outreach effectiveness question is not "which message works" but "who initiates." When the system initiates (auto-enrollment), participation is 3-4× higher. When the customer must initiate, most don't — not because they don't need help, but because navigating program eligibility is itself a barrier. Vermont's Act 142 found "there is a need for benefit 'navigators' to help guide recipients to available programs."
Sources: VT BED auto-enrollment (3%→12%, 219→776 customers) — Act 142 Final Report, VT PUC, Dec 1, 2025, pp. 29-30. VT BED projections (17% by Dec 2026) — same. GDS Associates "fewer than half" — GDS Associates Assessment of GMP's EAP, Nov 2019, commissioned by VT DPS. PA PECO 83.7% via 30 CBO sites — BCS Universal Service Report 2022. PA data-sharing timeline (Apr 2018→Nov 2024) — PA PUC presentation, "Agency/Utility Data Sharing," May 7, 2024, puc.pa.gov/media/2976; DHS 2024-25 LIHEAP announcement. WI streamlined eligibility — Focus on Energy 2025 Income Eligibility Guidelines. WI auto-enrollment (Energize Wisconsin) — NASEO, "Community Solar for All," Oct 2024, pp. 31-33. MA Community First Partners (52 communities, $85.5K/yr) — DPU 24-140 through 24-149, Order, Feb 28, 2025, Section XIII.F, pp. 291-297. MA <10% LI HPs — EEAC C-Team, "2025-2027 Draft Plan Initial Review," Slide 21 (~9% LI share). MI contractor word-of-mouth — Consumers Energy CCHP Evaluation Report, p. 5. VT "benefit navigators" — Act 142 Final Report, p. 5.