Auditors tend to read backbilling rules defensively — how far back can the utility come after my client for an undercharge. That half matters, but the same provisions frequently govern how far back the utility will adjust in your favor, and the two periods are not always symmetric.
Things worth checking in your state.
Whether the limitation period is stated in the commission rules, the utility tariff, or both, and which controls where they differ. I have seen tariffs that are more restrictive than the rule and were being applied anyway because nobody challenged them.
Whether the clock runs from the date of the erroneous bill, the date of discovery, or the date the customer notified the utility. This single detail changes the recoverable window more than anything else in the provision.
Whether there is an exception for utility error as distinct from meter error, and whether either extends the period. Several states treat a mis-set multiplier differently from a failed meter.
Whether the limit applies at all where the customer, rather than the utility, identified the error.
The reason this matters practically: a finding that is worth thirty months of recovery under one reading and twelve under another is a very different conversation with a client. Work it out before you quantify, not after.
Things worth checking in your state.
Whether the limitation period is stated in the commission rules, the utility tariff, or both, and which controls where they differ. I have seen tariffs that are more restrictive than the rule and were being applied anyway because nobody challenged them.
Whether the clock runs from the date of the erroneous bill, the date of discovery, or the date the customer notified the utility. This single detail changes the recoverable window more than anything else in the provision.
Whether there is an exception for utility error as distinct from meter error, and whether either extends the period. Several states treat a mis-set multiplier differently from a failed meter.
Whether the limit applies at all where the customer, rather than the utility, identified the error.
The reason this matters practically: a finding that is worth thirty months of recovery under one reading and twelve under another is a very different conversation with a client. Work it out before you quantify, not after.