Inside This Issue:

• I'm Y2K OK, You're Y2K OK
• Crossword Puzzle
• Telephone Billing Groups Criticize FCC For Failure To Act On LEC Billing Practices
• Goodbye Track it! Hello Interactive Advantage
• Oops!

I'm Y2K OK, You're Y2K OK. If you are reading this, we obviously both survived. However, there is considerable reason for concern about some of the other hazards that remain as a threat to your business or organization in the next millennium. Read on.

Representatives from local carriers, interexchange carriers, and information service providers met under the auspices of the FCC Common Carrier Bureau in Washington on November 30, 1999. The agenda announced by Larry Strickland, Chief CCB was to devote the first hour to reviewing the results of anti-cramming efforts undertaken the previous year and to spend the second hour discussing network access by dial-around providers. At the heart of these discussions was the role of the local exchange carrier(s) in providing billing name and address to those companies providing services accessed through casual dialing plans. More important to most of the attendees was access to the Incumbent Local Exchange Carrier (ILEC) billing envelope.

Since Mr. Strickland failed to reappear after the mid-session break, it was apparent that his main interest was in reciting some statistics showing improvement in cramming incidents (down 65%), declaring a victory for consumers, documenting the fact that he had met with industry representatives to address their concerns, and retiring from the fray with a self-congratulatory flourish.

Not so fast! This is a $100+ Million* problem for the interexchange carriers. So, despite the FCC's willingness to ignore RBOC anti-competitive behavior toward information providers, the MCI and Sprint lawyers will not be dismissed so easily. MCI is experiencing $20 Million in unbillable casual long distance calling because without billing name and address (BNA) provided by competitive local exchange carriers (CLECs), they can't provide the billing detail to the incumbent local exchange carriers (ILECs) who perform their billing. (*$100 Million figure obtained by extrapolation from MCI's market share.)

Members of CERB, (The Coalition to Ensure Responsible Billing, OTE: 4/99) pointed out ILECs are restricting their contracts with third party billers, even as cramming is decreasing. For example, U.S.West had made an announcement that they would cease billing for non-usage sensitive services (e.g. voice mail) on December 1,1999. This announcement came despite assurances just a month earlier by U.S.West that no interruption in billing would take place. And U.S. West has placed a $25 price cap on billing for services which compete against U.S. West services priced at $49.

MCI WordlCom representatives made the point that telephone number (TN) based services must be accessed through the LEC. And the LEC bill is the only affordable option for presenting charges for those services. MCI stated that they currently block 472 ILECs from accessing their network for casual calls because they can't bill for those services without the BNA. Sprint representatives pointed out that an economic study they funded showed no significant alternative source for billing for casual services beyond the LEC billing envelope. This study (see web edition) was performed by economists formerly employed by the FCC and DOJ and supports the findings in the Billing Reform Task Force (BRTF) study. (www.ei.com/publications.number.pdf)

Problems in billing for pay-per-call and other casual services will only get worse as IXC billing agreements with the RBOCs begin to expire - unless the FCC takes some action. IXCs are reporting price increases on the order of 100%, BEARING NO RELATIONSHIP TO ACTUAL COSTS.

Virtually all attendees (except the RBOCs and the absent U.S.West) requested that the FCC revisit the issue of billing (which was deregulated in 1986) and encouraged the formation of a third party information source of billing name and address information, going beyond the information currently contained in the Line Item Database (LIDB) provided by carriers and shared for a per use fee. As discouraging as it was to witness Mr. Strickland skip the second session of the meeting, it was even more disappointing to hear his deputy announce 'there is nothing I can do' on the eve of cessation for billing for thousands of customers in U.S. West territory.

Since ignoring the original MCI petition for rulemaking in this area in 1997, the FCC has amply demonstrated their ability to 'do nothing' by also ignoring the other requests for relief on file at www.fcc.gov, go to electronic filing system, search on RM- 9108.

A statement issued by the Billing Reform Task Force (BRTF) immediately following the proceedings appears in full on page 3..

Copyright ã 2000 Hattrick Group

Instructions

•  Solve the puzzle- $100 CASH PRIZE! 
• Call 1-800-344-7144, or 
• Complete the web entry form, or 
• e-mail or fax your answers 
• Ties decided by drawing 
• Must be a registered subscriber to win (call 202-371-8360, FAX 1-800-533-2329 or e-mail ote@telecompute.com.) 

Reminder: any answer may contain letters, numbers, or a combination thereof. The U.S. telephone keypad is the reference for number/letter combinations, with "Z" appearing on the "9" key on some sets.. 

January Puzzle


ACROSS 

1. This U.S. government levy has mushroomed to $5 Billion annually (abbr.) 
2. Bodies responsible for regulating what goes into LEC billing envelopes 4. Epithet for FCC Commissioner Harold Furchtgott-Roth 
5. Inefficient taxation of telephone services produces losses to consumers in the ____ of $Billions 

DOWN 
1. Taxation based upon ____ is the least efficient. 
3. There are how many sources for information related to FCC positions? 

November Answers

Note: Although many combinations of letters or numbers may 'fit' into a space, the only acceptable answer(s) are those programmed to be accepted by the Crossword Callä program. All entrants are encouraged to check their answers against the telephone version.

Sandra Golding could have been our winner in November, had she followed this helpful hint.

Copyright ã 2000 Hattrick Group

Telephone Billing Groups Criticize FCC For Failure To Act On LEC Billing Practices (Washington - 12/1/99)

Two groups representing competitive billing companies today expressed their dismay over the Federal Communications Commission's failure to respond to moves by the local exchange carriers (LEC) to terminate billing and collection services for products that the LECs intend to sell.

U.S.West has notified its customers that as of today it will no longer provide billing and collection services for voice mail, Caller ID, Internet access, and other competitive services.

On November 30, the FCC held a two-hour hearing on LEC billing practices. The forum was scheduled in response to a petition for rulemaking filed in 1997 by MCI and a more recent chorus of complaints from service providers that LEC billing practices are exclusionary, discriminatory, and anti-competitive.

Industry representatives expressed their dismay at the perfunctory nature of the hearing, and the fact that U.S.West was invited but did not attend.

"The FCC abdicated its legitimate regulatory role, its responsibility to competitive service providers, and American consumers," said Peter Brennan, co-chairman of the Billing Reform Task Force, a coalition of telephone service providers and competitive billing companies.

Another industry group, the Coalition to Ensure Responsible Billing (CERB) noted that it had joined the FCC in working to police cramming, or the posting of invalid charges to customers' phone bills. But it said, "Solutions to cramming cannot provide a smokescreen or excuse for anti-competitive maneuvers that allow LECs to take unfair advantage of their monopoly position as billers."

At the hearing, the BRTF and CERB presented a letter to Chairman William Kennard signed by more than 50 service providers, expressing the companies' outrage over the U.S.West action. The letter stated: "The question is not whether the FCC has authority to regulate billing and collections. At issue is whether the FCC will act to protect competition and consumer choice."

The FCC declined to regulate LEC billing in 1986, contending that "sufficient competition" existed "to allow market forces to respond." The BRTF, however, recently completed an economic study that asserted that there were no competitive alternatives to LEC billing and collection.

"We were encouraged when the FCC scheduled a meeting to discuss our concerns," said Brennan, "but disappointed that the staff members who attended showed little interest in really rolling up their sleeves, talking about our study, finding out about the details, and addressing issues that threaten the future of our industry".

Brennan noted that with four LECs in attendance, as well as representatives of the billing industry, MCI/WorldCom and Sprint, "the FCC truly missed an opportunity to engage both sides in a serious dialogue."

Among other things, the billing companies cited the "take-it-or-leave-it" approach to billing contract negotiations, the loss of their rights to audit LEC records, the lack of adequate billing data and the excessively high charges that LECs have imposed on billing services.

For further information, contact:

Billing Reform Task Force

Copyright ã 2000 Hattrick Group

Copyright ã 2000 Hattrick Group

Oops! That was Bell Atlantic's reaction in December upon learning that when re-programming the switches in the Baltimore area to accommodate new area code overlays, they forgot to include 976 numbers. IP's pay-per-call program call counts continued to deteriorate over a period of months as the changes were made on an incremental basis. Only when it became apparent that everyone's traffic couldn't be falling off at the same time did technicians investigate the problem.

Monopolists Unite. In November (OTE 11/99: Government Schizophrenia) we told you about the U.S. Government requiring that Microsoft products be used exclusively in electronic filing. Microsoft has also received a boost from AT&T - or should I say, AT&T has given customers a blind eye. Let's start with a simple thing like 900 compliance. AT&T has discontinued printing 900 Service Guidelines. When you do find the guidelines on their web site, they are impossible to download without Microsoft software. Despite AT&T spokesperson Karyn Knudsen's assertion that prospects can "call for a copy", I found no phone number. While I have nothing against Bill Gates, I believe consumers and customers alike deserve a choice. For that reason, web edition readers will find a copy of the AT&T 900 Guidelines converted to HTML and readily available for all to read or download.

W. E. Miller, Jr.
Editor

Copyright ã 2000 Hattrick Group