Wholesale: Products & Services

Open Product/Process CR PC102802-1 Detail

Description Of Change

- Pre-ordering (http://www.qwest.com/wholesale/clecs/preordering.html),

- LOA/POA (http://www.qwest.com/wholesale/preorder/index.html), and

- the IMA User’s guide (http://www.qwest.com/wholesale/downloads/2002/020916/ugpreorder_101_091302.pdf).

The Pre-Ordering website states "Before initiating activity, obtaining a CSR and placing orders on behalf of an end-user, you are required to have a Letter of Authorization or Proof of Authorization giving you authorization to do activity on their behalf." In a separate paragraph, the website provides "While it is not necessary for the LOA to accompany your request, the indication of authorization is required when you request a CSR for an account owned by Qwest or another CLEC." The initial reference to “Letter of Authorization or Proof of Authorization” by itself is fine, but the later reference only to "LOA" suggests written approval from the customer is required for access to the CSR. This is not the case. AT&T understands that customer authorization is required, but a written authorization is not. See 47 CFR Section 64.2007(b). This section of the federal rules identifies the methods by which a carrier may obtain customer approval to access CPNI. It states that "A telecommunications carrier may obtain approval through written, oral or electronic methods." State requirements in the Qwest territory largely mirror the federal rules.

The LOA/POA document states "Prior to obtaining records or placing orders for an end-user you must obtain permission from the end-user to act on their behalf in matters pertaining to the communications services." The following paragraph states "Proof of authorization can be arranged through a Letter of Agency" -- indicating there are options for obtaining authorizations from the customer. The third option cited is "oral authorization verified by an independent third party (with third party verification as POA)." Third party verification is necessary for a transfer of service, but is not required just to view a CSR. The website further states "While the Letter of Agency need not accompany your request for records or services, the indication of agency authorization is a required field entry when you request customer service records or submit Local and Access Service Request forms." As written, this language seems to require a written letter of authorization from the customer in order to view customer records. This is not consistent with the federal and state rules referenced above.

In the IMA user’s guide, "Reviewing Customer Service Records", 10.01 page 1-18 also provides that "Proof that a CLEC has received a Letter of Authorization (LOA) is required if the CLEC attempts to retrieve a CSR for a customer account owned by Qwest or another CLEC". Once again, this language suggests that a written letter of authorization is required. It is not.

While AT&T understands it is necessary to obtain customer consent prior to reviewing CSRs, it is not necessary to obtain written consent or third party verification of oral consent. Qwest does not have the authority through its PCAT, or otherwise, to demand more of CLECs than applicable law requires. AT&T would like to believe that the Qwest language referenced in this CR is simply inadvertent and does not represent Qwest’s intent to require more of CLECs than applicable law requires. However, AT&T does find this documentation troubling and believes that it is important that Qwest clean up its documentation to reflect what is required by applicable law. Please make these corrections and clarifications as soon as possible to avoid further confusion among Qwest’s CLEC customers. Suggestions AT&T would offer include: (i) do not use LOA interchangeably with other forms of authorization that may be obtained; and (ii) simply refer to applicable law in the places where the requirement for authorization needs to be referenced.

Expected Deliverable

AT&T expects Qwest to provide uniform instructions, in accordance with applicable law, within 60 days of submission of this CR.

Project Meetings

02/19/03 February CMP Meeting This CR is in development status and Donna Osborne-Miller with AT&T said that Qwest will incorporate the PCAT changes requested, the submitted comments, and they would like to leave the CR open another month. This CR will remain in development status.

01/15/03 January CMP Meeting Michelle Thacker with Qwest gave an update on this CR. Documentation for IMA will be effective 1/21/03 with IMA release 11.01. PCAT documentation is targeted to be available in late January. LSOG documentation and Preparation Guide will be available with the 12.0 IMA release in April. This CR will stay in Development status.

12/18/02 December CMP Meeting Linda Sanchez-Steinke with Qwest presented the draft response to this CR and said that CLEC facing documentation and the IMA User’s Guide will be updated. AT&T agreed with the Qwest response and Liz Balvin with Worldcom asked if there would be updates to the Preparation Guide. Qwest will e-mail an answer to Liz Balvin’s question and include in meeting minutes. This CR will be moved to Development status.

11/20/02 November CMP Meeting Carla Pardee with AT&T presented this CR and said that three of the Qwest pre-ordering web sites have different requirements ranging from oral to written approval prior to CLECs reviewing the customer service record. AT&T Legal interpretation is that only oral approval from customers is required prior to reviewing the CSR. Qwest will present the draft response at the December CMP Meeting.

CLEC Change Request Clarification Meeting

November 5, 2002, 3:00 p.m. (MT) Conference Call 1-877-554-8688 PIN 1930099 # PC102802-1 Correction/clarification of Qwest documentation (PCAT, IMA User’s Guide, etc.) describing customer authorization requirements for retrieval of CSR’s.

Carla Pardee, AT&T Mike Johnson, Qwest Sharon King, Qwest Cap Hamilton, Qwest Beth King, Qwest Michelle Thacker, Qwest Linda Sanchez-Steinke, Qwest

Introduction of the participants on the Conference Call was made and the purpose of the call discussed.

Review Requested (Description of) Change The description of change requested in the CR was reviewed. Carla indicated that AT&T is asking that there be consistency in all Qwest documentation associated with the review of customer service records (CSRs). AT&T Legal interprets the wording in the following Qwest websites to be inaccurate according to federal rules, 47 CFR Section 64.2007(b) - Pre-ordering (http://www.qwest.com/wholesale/clecs/preordering.html), - LOA/POA (http://www.qwest.com/wholesale/preorder/index.html), and - the IMA User’s guide (http://www.qwest.com/wholesale/downloads/2002/020916/ugpreorder101091302.pdf) AT&T’s interpretation is that approval to view the customer service record (CSR) can be in written, oral or electronic format.

Confirm Areas & Products Impacted Carla indicated that all products are impacted.

Confirm Right Personnel Involved Qwest confirmed that the right personnel were involved in the conference call.

Identify/Confirm CLEC’s Expectation Carla confirmed that AT&T is not disputing oral approval from customer to review CSR. The documentation wording sounds like the CLECs have to get written permission from customers to view their CSR and AT&T is asking that Qwest documentation be revised.

Establish Action Plan (Resolution Time Frame) This CR will be presented by Carla at the November CMP Meeting.

CenturyLink Response

Carla Pardee LSAM Manager AT&T

SUBJECT:Qwest’s Change Request Response - CR # PC102802-1 (Correction/clarification of Qwest documentation (PCAT, IMA User’s Guide, etc.) describing customer authorization requirements for retrieval of CSRs.)

This is in response to AT&T’s Change Request CR PC102802-1. This CR requests that Qwest clarify and correct as needed Qwest documentation (PCAT, IMA User’s Guide, etc.) that describes customer authorization requirements for retrieval of CSRs.

Qwest accepts this CR and will review and clarify CLEC facing documents pertaining or referencing customer authorization requirements.

The IMA User Guide 11.01, is targeted for review in late December and Qwest External Documentation is targeted for review in late January.

Sincerely,

Michelle Thacker Process Specialist Qwest