Wholesale: Products & Services

Open Product/Process CR PC032801-4ES Detail

Description Of Change

Project Meetings

CenturyLink Response

Document Overview

The purpose of this document is to describe the different factors that drive rate changes, as well as outline the process by which Qwest will notify CLECs of these changes. It is important to note that contractual obligations may supersede the guidelines outlined below.

Rate Change Catalysts and Notification Processes

Qwest has identified five main categories of items that drive rate changes – validation efforts, cost docket changes, interconnect agreements and amendments, bill errors/disputes, and new products/product pricing changes. Brief descriptions of these categories and the process by which the CLECs are notified are found below:

? Rate Validation Efforts

Qwest recently carried out a rate validation effort, to verify that bills properly reflect the rates ordered by the State Commission and/or the rates modified as a result of contract negotiations. Following the completion of the Rate Validation efforts, profiles will be available for each CLEC by state, by product which will detail the rates they are currently being charged.

Qwest will develop a process by March 1, 2002 so that if Qwest undertakes comprehensive validation efforts in the future, notification of any corrections will be provided to the CLECs at least 10 days before changes are made to the billing systems. Notification will include the product affected, the currently billed and the new rate, the effective date of the rate change, and the rate implementation date.

? Cost Dockets

Cost dockets are state-mandated rates, determined by the Public Utilities Commission (PUC) for each state. Generally, state governments do not mandate notification timeframes for cost docket rate changes, however, Qwest will be implementing a new process in which CLECs will receive two notifications.

The first notification to the CLEC occurs when an interconnect agreement is updated in Qwest’s interconnect agreement repository. At this point, the CLEC can request a copy of the updated interconnect agreement from their service manager. By March 1, 2002 Qwest will develop a process for a second notification to occur at least 10 days prior to the implementation of the new interconnection agreement rates in the billing system. The notices will contain information regarding the product that is changing, the new rate, the effective date of the change, and in the case of the second notice, the planned implementation date.

? New/Existing Interconnect Agreements

The purpose of a new interconnect agreement is to establish billing for all products included in the agreement. Each product is assigned a negotiated or a state-mandated rate. Amendments are used to either add a new product to an interconnect agreement, or change the rate of an existing product. CLEC Rate Notification Process

The CLEC is notified when an interconnect agreement is received by the contract implementation specialist. A second notification, that identifies CLEC ordering can occur, is initiated by the Service Manager when the agreement is finalized. Note: The PUC will send Qwest & the CLEC notification when they accept or reject an interconnect agreement.

? Bill Errors/Disputes

When a CLEC reports a rate discrepancy, the Billing SDC will fix the bill to reflect the correct In addition the SDC will notify a Contract Implementation Specialist to initiate a system rate change so that the rate can be fixed going forward.

If a Billing SDC notices that a CLEC is being charged the wrong rate they will fix the bill to reflect the correct rate and call the CLEC to notify them of the change to their bill. In addition the SDC will notify a Contract Implementation Specialist to initiate a system rate change so that the rate can be fixed going forward. ? New Product Implementation and Product Price Changes

CLECs will be made aware of the availability of new products through the CMP process. On an individual CLEC basis, interconnect agreements can then be amended to include the new product. Please refer to the New/Existing Interconnect Agreements section above.

Occasionally, Qwest product managers initiate product rate changes (for non-cost docketed products) as a result of a costing analysis. These new rates are loaded into the SGAT and available to new CLECs through the creation of interconnect agreements, and to existing CLECs through the interconnect agreement re-negotiation/amendment process.

? General

If at any time a CLEC has a question about a specific product or rate, Qwest Billing Representatives are available to handle such inquiries. To request a profile of all rates by state, by product, a CLEC should contact their Service Manager.

Wholesale Product Marketing

November 9, 2001

Lynn Powers Vice President, Eschelon Telecom, Inc.

CC: Matthew Rossi

This letter in response to your CLEC Product & Process Change Request Form number PCCR032801-4. ? Request - Qwest should implement a process to provide advance notice to CLECs before changes are made to the CLEC’s profile and rates in Qwest’s systems. The notice should be sufficiently detailed to allow the CLEC to understand the implications of the change and should be provided sufficiently in advance of any change to allow the CLEC to object, if necessary. A process should be put in place to handle objections to changes before the changes are made. ? Response – The profile problems Eschelon was experiencing are based on two different root causes and Qwest is committed to improving the overall process. Listed below are the root causes of the recent problems and our process improvements and recommendations: 1. Qwest performed a scrub of the database and made changes without customer notification or input based on the output of the scrub. Effective 7/18, Qwest implemented a process to notify Co-providers when USOCs available to them are deleted from the ordering systems for normal maintenance purposes. This notification will happen at least 10 days in advance of the actual deletion, and would be provided through the Service Manager or via a direct letter. In the case of a USOC being deleted for all Co-providers, a common letter will be sent to all. In the case of individual Co-provider effects, the Service Manager will provide this notification directly to the affected Co-provider. An exception to this advance notification might be made in the case of system outages or other extreme events, however these should be very rare. As a normal course of business, ten days advanced notification would be provided. 2. Recently Eschelon experienced a problem with placing orders for Coordinated Loop cuts in Colorado. This is where Eschelon turned up their switch for the first time and began attempting to place orders. The root cause of this problem was based on recent agreements between the companies and the uncertainty of which rates needed to be loaded into our systems for this work. As soon as we discovered the system needed a rate in order to process the orders, we immediately escalated internally. Based on your experience, Qwest wants to take an additional look at our internal processes to determine if cross-functional resources and additional processes are required.

? In the August CMP meeting, Eschelon asked how to obtain a current copy of a CLEC’s valid USOCs to be used for verification. This is done on a state by state basis via the Service Manager, who can have a report pulled from the CPS (formerly known as CPPD) system with all USOCs loaded for that CLEC by state. This report would contain all USOCs that the CLEC can order in that state. This would enable a CLEC to proactively identify circumstances that cause problems like those in paragraph number 2 above.

? At the October meeting, Eschelon asked for further clarification on the process of notifications for cost docket and contract/amendment implementations. As discussed in the May and August CMP meetings, there are processes already in place for these situations. In the case of rate case or cost docket implementations that affect multiple CLECs, Qwest sends a letter to each CLEC affected informing the CLECs of the implementation. This notification is generally at least 10 days before the implementation. In the case of individual contracts or amendments that are implemented for a specific CLEC, that CLEC’s service manager will notify the CLEC of the implementation date, and the particular products being implemented. This notification will be done when the implementation date is determined. ? For new product introductions, current practice is that a product announcement is sent to all CLECs advising of the availability date for that product at least 30 days prior to the availability. This is currently being discussed in the CMP Redesign meetings. ? As communicated in a November 1st notification, Qwest is currently undertaking a major validation of rates for all CLECs in all states. To the extent rate discrepancies are discovered, Qwest will make the necessary changes to the rate tables in order to put those rates in sync with the current contracts and cost docket rulings. At the conclusion of that effort, targeted for early December, Qwest will send a USOC report to each affected CLEC so that the CLEC can validate the rates loaded for their USOCs.

I believe this addresses all the issues raised by this CR. If you would like to discuss the response in detail. I can be reached at (303)896-8346 or azimmer@qwest.com. Have a good day!

Alan Zimmerman Qwest Wholesale Process Manager

-- August 3, 2001

Lynn Powers Vice President, Eschelon Telecom, Inc. CC:Matthew Rossi

This letter in response to your CLEC Product & Process Change Request Form number PCCR032801-4. Request: Qwest should implement a process to provide advance notice to CLECs before changes are made to the CLEC’s profile and rates in Qwest’s systems. The notice should be sufficiently detailed to allow the CLEC to understand the implications of the change and should be provided sufficiently in advance of any change to allow the CLEC to object, if necessary. A process should be put in place to handle objections to changes before the changes are made. Response: As discussed at the 5/14 CICMP meeting, processes already exist within Qwest for notifying Co-providers of changes when rate cases or other regulatory activity has occurred. There are also existing processes enabling service managers to advise Co-providers of changes due to contract implementations or changes. There is no process for notifying Co-providers when USOCs are changed as a course of maintenance within Qwest systems.

Effective 7/18, Qwest implemented a process to notify Co-providers when USOCs available to them are deleted from the ordering systems for normal maintenance purposes. This notification will happen at least 10 days in advance of the actual deletion, and would be provided through the Service Manager or via a direct letter. In the case of a USOC being deleted for all Co-providers, a common letter will be sent to all. In the case of individual Co-provider effects, the Service Manager will provide this notification directly to the affected Co-provider. An exception to this advance notification might be made in the case of system outages or other extreme events, however these should be very rare. As a normal course of business, ten days advanced notification would be provided.

If you have any questions or comments about this policy, feel free to contact Alan Zimmerman at (303)896-8346 or azimmer@qwest.com. Have a good day!

Alan Zimmerman Qwest Wholesale Process Manager