Wholesale: Products & Services

Open Product/Process CR PC100401-2 Detail

Description Of Change

Given the above, we believe that QWEST should send us rated usage records so that we can, on QWEST behalf, bill the SBCT customer that apparently accepted the call. In other words, we should receive rated records from QWEST via the standard incollect/outcollect process that is handled through CMDS. QWEST was also billing these calls on our paper bills (at a resale discount), but this is incorrect, these calls are not subject to a resale discount, since the calls were made not on a resale or facilities basis. Qwest did state that the discounted rates should have not been applied (which SBCT agrees w/). We dispute Qwest billings to SBCT of these calls.

Qwest is the only ILEC in that their daily usage file doesn’t contain rated records, and in addition, Qwest has told SBCT that we should use the calls reported on the summary bill and bill SBCT's customer at SBCT's rates.

We again explained that we could not rate the call, since the charges are QWEST's. We noted that we are not able to use the summary bill that QWEST talked about and indicated that industry practice would be for QWEST to send rated EMI records.

Project Meetings

Subject: FW: Clarification of unrated vs. rated calls, Qwest Change Date: Wed, 31 Oct 2001 10:05:59 -0600 From: "DAMPIER, REGGIE (SBCSI)" To: "Zimmerman, Alan" ,"'pwirth@qwest.com'" CC: "NAPPIER, THOMAS G (SBCSI)" ,"MUELLER, KAREN (SBCSI)" ,"DAMPIER, REGGIE (SBCSI)"

Our SME states that if a call originates w/ a Qwest customer, such as these particular collect inmate calls do, OBF standards should be followed and the calls should be rated (this is response for Questions: 1) is this change request just for the inmate collect coin calls OR is our change request pertain to ALL incollects calls? and 2) the request to rate these types of calls pertains to resale, UNE, and facility-based (same as UNE)?

Reggie Dampier OBC 905 Chestnut, Suite 26-T-03 St. Louis, MO 63101 314-235-6369 RD5335@momail.sbc.com

-- Alignment/Clarification Meeting 1:30 p.m. (MT) / Monday 29th October 2001

1-866-289-7092 PC741-1286 # PCCR100401-2 Provision of Rated vs. Unrated usage, when applicable, regardless of CLEC status (resale, facility based, etc.)

Attendees: Peter Wirth - Qwest Alan Zimmerman - Qwest Reggie Dampier - SBC Telecommunications

Meeting Agenda: 1.0 Introduction of Attendees All attendees introduced. 2.0 Review Requested (Description of) Change {review long description from change request, confirm with all parties there is agreement on the change requested} CR description discussed & reviewed by all parties. Additional clarification from SBC required for the following: 1) Does provision of rated vs. unrated usage address all incollect or just inmate calls?; and 2) Does rated vs. unrated usage address resold or UNI, or both? SBC to provide input back to Qwest.

3.0 Confirm Areas & Products Impacted {read from change request, modify if needed} Billing.

4.0 Confirm Right Personnel Involved {ensure the Qwest SME can fully answer the CLEC request. Confirm whether anyone else within Qwest has been involved with this issue, or whether we need to bring anyone else in} Parties agreed correct personnel were on call. Karen Mueller, SBC identified as SBC SME for purposes of this CR. Contact: (314) 235-0880.

5.0 Identify/Confirm CLEC’s Expectation {Identify specific deliverables from CLEC – what does Qwest have to do in order to close this CR? (in measurable terms ie provide a documented process, change a process to include training etc)} Obtain rated equivalents for applicable records currently unrated originating from Qwest.

6.0 Identify any Dependent Systems Change Requests {Note any connected CRs and the potential impacts} None identified.

7.0 Establish Action Plan (Resolution Time Frame) {state action required, who will be responsible and by when} Proceed with CR evaluation and response development.

- Letter (email) from Debbi Soriano, SBC, dated Oct 25, 2001, regarding PCCR 100401-2 To our fellow CLECs, operating within Qwest franchised territories:

I send you greetings, and wish you well.

As the billing Subject Matter Expert for SBC Telecom, Inc. (SBCT), my job duties include reviewing interconnection agreements to ensure that our billing organization has the appropriate language in place to process our end-user data, access data, reciprocal compensation data, and to ensure that our billing, and data feeds are correctly addressed.

The purpose of this letter is to provide clarification of a process change that SBCT has submitted via Qwest's change management process.

Qwest personnel have yet to contact me (as per their guidelines), to clarify this new issue. Therefore, I've included additional verbiage below, in order to help clarify the issue generating SBCT’s change request. SBCT would like your support on this issue, since it is likely your company is experiencing the same difficulty. It is SBCT’s goal to have Qwest resolve the issue in such a way that industry guidelines are met so that each company can accurately and effectively bill its end user customers.

In short, the issue is that alternately billed calls originated by Qwest end-user customers, and billed to SBCT end-user customers are being sent as unrated EMI records off of the daily usage file. Specifically, the calls that are of concern to SBCT are collect coin/inmate calls (10-01-31 records with Indicator 01=1 and Indicator 16=2). SBCT has verified that the billing (and terminating) telephone numbers are SBCT’s end-user customers. SBCT has also verified that the originating numbers are inmate facilities served by Qwest.

Normally, in the voice telephony world, all of us bill on behalf of other telco companies, since our end-user customers frequently travel to other places and have a need to place alternately billed calls. Therefore, a process, such as CMDS, has been put in place to assist in the billing and revenue settlements associated with these calls. Each of us uses either direct feeds or CMDS to deliver these types of calls to each other. The expectation being that the originating company will send rated EMI records to the billing company to eliminate the need for each of the companies to have to maintain rating tables for the entire country and to ensure that the company who incurs the cost for transporting the call also receives the revenue.

SBCT contends that Qwest is not relieved of this obligation just because a CLEC is serving its end-user customers via resale of Qwest service. The alternately billed calls in question still belong to Qwest. Since these calls are originated by Qwest customers and transverse the Qwest network, Qwest is entitled to the revenue. Only Qwest is able to determine what rates should be charged to recover the cost of setting up and transporting the call. Therefore Qwest should send rated EMI records via a CMDS or a direct feed process just as they would if the billed customer were not served via resale of Qwest service.

The process Qwest is using is wrong. Qwest is treating the rating and billing of alternately billed calls differently depending upon whether a CLEC customer to be billed, is provided service via resale of Qwest facilities or using its own facilities or being 3rd number billed for calls that do not fall under the scope of an ICA (e.g., our end-user customer has accepted charges for a call incurred within Qwest territory by a Qwest end-user customer). SBCT has repeatedly explained to Qwest personnel that SBCT could not rate the calls, since the charges are Qwest's. SBCT noted that industry practice would be for Qwest to send rated EMI records. Qwest did not agree.

Furthermore, Qwest personnel indicated that a CLEC should use the CLEC’s rates for the calls that Qwest bills on SBCT’s summary paper bills, and transpose those rates onto each call recording to bill its end-users customers. This is somewhat difficult to do. First, SBCT (or any other CLEC) would have to examine each summary bill received from Qwest and rate the unrated calls received via the daily usage file. Then get the SBCT rated calls into the files in order to guide and bill these calls to the end-user customers on behalf of Qwest.

In short, the solution to this problem is simple. Qwest should record and rate calls that belong to Qwest, and correct the edits in place at Qwest that incorrectly guide these unrated calls to any CLEC, e.g., do not use the billing telephone number edit that incorrectly guides these unrated calls to a CLEC. Furthermore, Qwest should deliver the rated calls per normal industry practices (as we all do), so these rated calls can be placed on the end-user customer's bills by the 'bill to' company.

If you have any comments, suggestions, etc., I can be reached at the below contact numbers.

Sincerely,

Reggie Dampier

Reggie Dampier OBC 905 Chestnut, Suite 26-T-03 St. Louis, MO 63101 314-235-6369 RD5335@momail.sbc.com

CenturyLink Response

Reggie Dampier, Business Manager SBC Telecom, Inc.

Cc: Susan Burson Michael Buck

This letter is in response to your CLEC Product & Process Change Request (CR) Form No. PC100401-2 "Provision of Rated vs. Unrated usage, when applicable, regardless of CLEC status (resale, facility-based, etc.)."

In order to accomplish this request, modifications are required in the Qwest Customer Records Network Information (CRIS) system. Hence, this request needs to be considered as part of the Qwest Systems Change Management Process. Qwest is proposing to close out this Product & Process CR, and has opened CR No. SCR112101-1 in the Systems Change Management forum so that the system issues can be properly considered.

Sincerely,

Alan Zimmerman Qwest Wholesale Billing Manager