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Tele-Tech Updates

April 2012

"Separating Intrastate from Interstate Minutes Post ICC Reform: Does it Matter?"

Fundamental changes to the Intercarrier Compensation system are raising new questions regarding billing and reporting practices. If intrastate VoIP minutes are being billed at the interstate rate, is there any need to identify the minutes separately?

Tele-Tech is always a proponent of ensuring all traffic is jurisdictionalized properly and reflected in the correct section of Access bills. With the FCC's decision to bill interconnected VoIP traffic at the interstate rate, it's all too easy not to separate interstate from intrastate traffic in favor of lumping it all onto the interstate portion of the bill.  After all, the amount billed will still be correct.

This practice is not only inaccurate, it can also adversely affect companies taking part in the National Exchange Carriers Association (NECA) pool.  Participating carriers contribute into the NECA pool and receive distributions based on the amount of interstate traffic they carry.  So, a misrepresentation of the amount of interstate traffic can cause distributions to be made in error.

Many billing companies have made the necessary changes to ensure intrastate VoIP traffic is accurately reflected on the bills they produce.  If you're unsure of how your biller will handle intrastate VoIP traffic or have your own billing system and don't know if the needed adjustments have been made, it's a good idea to check.

For more information, contact Kim Russo at KRusso@telecomdb.com or 843-879-5030.

"Groups Seek Clarification on Originating Access Charges"

Organizations with differing viewpoints on long-term access charge reform banded together recently to make a common request: that the FCC clarify the treatment of originating access rates for VoIP traffic in the USF and ICC Reform Order.

The subject became an issue after Verizon, in its February 24, 2012 comments to the FCC, stated that for VoIP-PSTN traffic, intrastate originating access rates are subject to the same transition as terminating charges.

Cbeyond, Earthlink, Frontier, Integra Telecom, the National Cable & Telecommunications Association, the National Telecommunications Cooperative Association, tw telecom and Windstream all disagree; and the group jointly wrote a letter March 8, 2012 asking the FCC to resolve this dispute.

The group's specific request for price cap carriers and competitive LECs that benchmark access rates to price cap carriers, is to cap VoIP-PSTN intrastate originating access rates at the rates in effect prior to December 29, 2011. Secondly, that the Commission would "place no limits on intrastate originating access rates for rate-of-return carriers and competitive LECs that benchmark to rate-of-return carriers."

Despite the backlash, Verizon maintains its stance. The company's regulatory affairs officer reiterated In a March 5, 2012 meeting with an FCC official, that "the text of (the) USF-ICC Transformation Order indicates that originating access charges for all PSTN-VoIP traffic is subject to interstate rates, not intrastate rates."

Commissioners have not yet responded to the requests.

"New Lifeline Rules in Effect"

Most of the rules adopted in the Lifeline Reform Order went into effect April 2, 2012. Commissioners approved the Order earlier this year, finalizing an incremental reform process that began in 2010. Lifeline is a component of the Universal Service Fund (USF) program that provides discounted monthly phone service for low income customers.

Following the directive of USF reform, Lifeline will also transition to supporting broadband service rather than the traditional telephone.

Fraud and abuse will be controlled by conducting independent audits every two years, establishing national eligibility criteria and creating a National Lifeline Accountability Database to prevent multiple carriers from receiving support for the same subscriber.

The FCC has already taken significant steps to implement some of those reforms. In June 2011, the Commission tightened rules to prevent carriers from receiving compensation for the same customer. An effort to screen duplicative service in 12 states has so far saved $33 million by eliminating 270,000 ineligible accounts. That program is expected to expand to other states this year.

Commissioners estimate the reforms will save $2 billion over the next three years.

"EUCL Rate Database for Lifeline Reimbursement"

Tele-Tech's EUCL database tells you exactly how much to report to the USAC when it comes to Lifeline reimbursement.  

Just a few pennies short can quickly add up to tens of thousands of dollars in lost revenue!  

With our accurate Lifeline reimbursement data, you can relax when the USAC comes calling for an audit. Our up-to-date tariff rates provide the documentation you need to back up Form 497. 

If you're interested in getting peace of mind, being accurate and saving time; please contact Kim Russo at KRusso@telecomdb.com or 843-879-5030.

 
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