Optimization of Deemed Data Collection Requirements

Deemed measures rely on the competing goals of accuracy and volume to ensure that gross claims are reasonable. In the current California electronic Technical Reference Manual portfolio, this balance is not always well aligned; as of PY2025, more than 40 measure packages, representing over 25 percent of the portfolio, have not been part of any savings claims since PY2022. This project addressed the need to better align data collection requirements with the measure parameters that materially affect total system benefit, total resource cost, and claim integrity. The project developed and piloted a framework for evaluating data collection burden across a representative group of five commonly implemented measure packages and two unused or rarely used measure packages in the California portfolio from 2023 to 2025. The approach combined electronic Technical Reference Manual permutation outputs, recent claims trends, stakeholder feedback, sensitivity analysis, and structured estimates of data collection cost by format and delivery type. This allowed the project team to compare the value of additional documentation against the benefits it protects. The results show that several medium and high effort documentation requirements are not tied to parameters that materially drive total system benefit or total resource cost. In some cases, data collection cost approaches or exceeds total system benefit, reducing implementer value and discouraging participation. The analysis also found that photo heavy and site access dependent requirements can become disproportionately burdensome at scale, especially for midstream, upstream, or low rigor delivery types. This project demonstrates that data collection requirements should be set deliberately before measure packages are introduced or revised. Requirements tied to sensitive parameters should be retained and automated where possible, while low sensitivity requirements should be simplified, removed, or replaced with clearer standard text to preserve enforceability without suppressing claim volume.