Wholesale: Products & Services

Archived System CR SCR112101-1 Detail

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.

Status History

Project Meetings

November 22, 2002 Email from SBC to Qwest: Peggy, thanks so much for your very prompt response! I concur with your actions. Take care, and thanks! Reggie Reggie Dampier OBC 905 Chestnut, Suite 26-T-03 St. Louis, MO 63101 314-235-6369 RD5335@momail.sbc.com

November 22, 2002 Email from Qwest to SBC: I received your email and will change the status of your submitted Systems CR to 'Pending Withdrawal' due to the fact that you do not wish Qwest to proceed with this effort. Please respond with your concurrence. This CR would then be in the December Systems CMP Meeting for the actual withdrawal. Thanks, Peggy Esquibel-Reed Qwest CRPM -- Systems

November 22, 2002 Email from SBC to Qwest: Peggy, Hope all is going well w/ you! At this time, SBC Telcom, Inc. is NOT interested in pursuing a fix or change within the Change Mgmt. Process to address the "Rated vs. Unrated" Issue. Our SBCT account manager, Ms. Debbi Soriano, will contact our Qwest Account Manager to finalize or work out details associated with this effort. If you have any questions or comments, please don't hesitate to contact me. Take care! Reggie Dampier Reggie Dampier OBC 905 Chestnut, Suite 26-T-03 St. Louis, MO 63101 314-235-6369 RD5335@momail.sbc.com

November 14, 2002 Email from SBC to Qwest: Peggy, got your msg., am following up on. Thanks, Reggie D. Reggie Dampier OBC 905 Chestnut, Suite 26-T-03 St. Louis, MO 63101 314-235-6369 RD5335@momail.sbc.com

November 14, 2002 Email from Qwest to SBC: Hi Reggie -- I am following-up on the above CMP CR. Is SBC ready for us to move forward with this work effort? Please let me know. Thanks, Peggy Esquibel-Reed Qwest CRPM -- Systems pesquib@qwest.com

July 18, 2002 CMP Meeting Discussion: Michael Buck/Qwest reviewed the history associated with the open action item. Reggie Dampier/SBC said that they don’t want this CR moved to a deferred status because SBC still feels that there is an issue. He also said that the Attorney’s from Qwest and SBC have agreed on the language and are now waiting on some firm dollar figures. Jeff Thompson/Qwest asked what firm figures Reggie Dampier/SBC was referring to. Reggie Dampier/SBC said the figures referred to the dollars/cost to do this. Jeff Thompson/Qwest asked whom SBC was working with from Qwest. Reggie Dampier/SBC said that he was working with theur Account Manager, Sue Griffeth. Michael Buck/Qwest said that Qwest could certainly look into that. Reggie Dampier/Qwest said that the legal folks are involved so it is out of his scope. Michael Buck/Qwest said that this CR will remain open and this action item is closed. Jeff Thompson/Qwest asked if this means we need to take a new action item. Michael Buck/Qwest said yes.

June 20, 2002 CMP Meeting Discussion: Michael Buck (Qwest) stated that Qwest is continuing to work with SBC on this CR. Connie Winston (Qwest) asked if Qwest could place this in ‘Deferred’ status. Michael Buck (Qwest) indicated that Qwest could work with SBC on the change of the status to ‘Deferred’ right before the July CMP meeting. There were no additional comments.

May 16, 2002 Systems CMP Meeting Discussion: Peggy Esquibel-Reed/Qwest stated that SBC is continueing to hold internal meetings before scheduleing the meeting with Qwest. The SBC Action Item remains open.

April 18, 2002: April CMP Discussion: Peggy Esquibel-Reed/Qwest stated that there has been some discussion between the attorney’s but a final decision is still pending. Alan Zimmerman/Qwest is ready to proceed with the change to provide rated usage but is still waiting for SBC’s official go-ahead to proceed.

March 21, 2002 CMP Discussion: SBC was not in attendance to provide an update Michael Buck/Qwest indicated that an offline meeting was held, unfortunately the SBC attorney was unable to attend meeting and so it has to be re-scheduled. Qwest is still waiting for the SBC attorney to contact Qwest. Peggy Esquibel-Reed/Qwest indicated that Pamela Johnson (Qwest attorney) noted that the meeting has not yet taken place (as of March 21) but hoping to have it next week.

March 8, 2002 Conference call held with SBC and Qwest participants. SBC legal, Adam, was unable to attend. The CR and Qwest's proposal were discussed. Dave/SBC agreed to talk with Adam and will ask Adam to call Michelle Meske/Qwest Legal for further discussion and resolution. Adam will advise Michelle if SBC will accept Qwest's proposal to send rated messages via the DUF (Daily Usage File) and continue sending paper bills.

February 21, 2002 CMP Discussion: Alan Zimmerman/Qwest stated that can change rating on the DUF so usage can be sent rated. There are contratual issues to change how the calls are rated. It was agreed that the Qwest Account Manager for SBC would schedule a meeting with legal and the SBC Account Team to discuss the Rated vs Unrated issues. Jeff Thompson/Qwest stated that the CR may need to be updated after the discussion has taken place.

Conference call with CLEC community - February 5, 2002 Attendee’s: Kathy Stichter, Eschelon Telecom Inc. Bill Markert, Eschelon Telecom Inc. Melissa Tomlinson, Eschelon Telecom Inc. Reggie Dampier, SBCT Nick Erso, SBC Karen Miller, Southwestern Bell Lisa McNabola, MultiBand Communications LLC Lynn Daudt, USLink Deb Hoffman, USLink Pam Zimmerman, USLink Sharon Janine John Midcontinent Communications Garth Kauffman, Iowa Telecom Mary Lohnes, MMI Nancy Vogel, MMI Pamela Johnson, Qwest Alan Zimmerman, Qwest Mark Pomeroy, Qwest Freddi Pennington, Qwest Peggy Esquibel-Reed, Qwest Sue Gwin, Qwest

Alan Zimmerman/Qwest stated that he could change how Qwest passes usage and start passing rated calls, with full retail rates. This would not be a contractual issue. Changing the rates is a contractual issue. Reggie/SBC stated that calls originating from inmates and billing to a 3rd number, originating in Qwest territory are in-collect, out-collect calls and shouldn’t be special. They are recorded by Qwest and should be rated by Qwest at the normal standard industry rates. Alan/Qwest stated that the telephone service was purchased by a reseller so the retail discount applies. There is an indicator on the EMI record, if it is a prison call, can rate via the daily usage feed (DUF). Karen Miller/Southwestern Bell stated if is a resold account, agrees would get unrated record and they would rate. Reggie’s scenario is not resold and should get rated record to bill the end user. The party placing the call is not a resold account. Alan/Qwest stated that Qwest is the earning company, as the originator of the call. Qwest can rate the call on the DUF at the full retail rates any time is alternately billed. Statement was made that need to look at the originator of the call: resale customer, resold services. Freddi Pennington/Qwest asked if changes would be for all CLEC’s. Alan/Qwest responded yes. Today the 10 records/calls are unrated, the 01 records are rated, standard EMI format. 17 & 18 records could be appended if ported. Reggie/SBC stated that SBC receives itemized calls on paper bills and shouldn’t, is not the normal scope of resold. Alan/Qwest advised that is where the contractual issue is. Karen Miller/Southwestern Bell asked a Qwest customer, originating in Qwest territory, billing to an SBC customer, would that be passed via CMDS or the DUF? Alan/Qwest stated that in the previously held clarification meeting, there was not a preference as to how the calls were passed. Would be passed via the DUF. Karen/Southwestern Bell stated that it should be via CMDS, not the DUF. Reggie/SBC stated that the DUF does contain rated and unrated usage. Stated that so many have moved away from CMDS. Nick Erso/SBC stated that the calls originating in Qwest territory is not expected to be seen on the bills. Alan/Qwest advised that could do a CMDS settlement The SBC/Qwest agreement states that resold customer usage is sent unrated. It was stated, by a CLEC, that if the call originates from Qwest, it is not a resold customer, it is a Qwest customer. Alan/Qwest stated that the purchaser of the service is the billing #. CLEC stated that an SBC customer accepted the charges but did not ‘purchase’. Peggy/Qwest asked if there were any objection’s to Qwest making the change. Melissa Tomlinson/Eschelon stated was okay with the change, as did several other CLECs. Melissa/Eschelon stated that she disagrees with what the purchasing customer is. Will do whatever if Qwest can send rated messages. Karen Miller/Southwestern Bell stated wants rated if Qwest customer only. If the originating number is SBCT and customer is in Qwest territory, wants unrated on the DUF. If the originating number is Qwest and the customer is in SBC territory, wants rated, unless the Qwest call is resold. Processes all resold usage the same and won’t change her system for Qwest only. Alan/Qwest stated that originating number guiding is not in the CR. Qwest stated that based on the discussion on what the request is, the level of effort has changed from medium to extra large. The CLEC’s want more people involved, do not feel there is enough billing representation on the call. Alan/Qwest stated that is willing to send all alternately billed records on the DUF as rated, based on the billing company not the originating company. CLEC’s again stated that not enough billing people on the call. Qwest agreed to schedule another call to discuss further.

01/17/02 CMP Meeting Discussion: AI Number 1 Provide Preliminary Qwest position on policy and contract implications: The Notice was sent out. Qwest has some contractual issues for charging discounted rates. This Action Item will be closed. Reggie Dampier/SBC stated that they are Qwest calls, I don’t care about the rates since they are yours. Reggie doesn’t want discounted calls on bills. These calls were taken off and now are putting them back on. Reggie stated that is an In-collect, Out-collect issue. Alan Zimmerman/Qwest stated that there are 3rd number billed calls to a resale customer, that’s why getting billed on a resale bill. Reggie/SBC stated that he didn’t know this was a resale call. Alan/Qwest stated that a 3rd party accepted the call so Qwest bills the 3rd party. Reggie/SBC stated he is still waiting for legal review from Qwest. He advised that this was the first he had heard that these were resold calls. Stated that he thought these were regular alternately billed calls, not UNE or resale. External call is out-collect, in-collect and 3rd # call out of territory. ….Should be rated by Bell South. Qwest footpath ….. don’t know what the rate is. Alan Zimmerman responded that Qwest could send tariffed rates and there wouldn’t be any contractual issues. When we change the way we bill, that’s where the contract issues come in. Alan stated that Qwest could send unrated usage with full retail rates, but will bill this as unrated usage. Terry/Allegiance and Bonnie/Eschelon requested take off-line. Karen Clauson/Eschelon stated that she wants to understand the issue. Karen asked if this is a retail Qwest customer. Then asked if this was originating/terminating in Qwest territory. Reggie Dampier/SBC stated that feels he is the middle man and doesn’t know the rates to bill. Leilani Hines/WorlCom stated that this is casual traffic. Alan/Qwest said there is a separate agreement or contract for that. Someone said this is like 10XXX traffic. Bottom line, a re-clarification call will be scheduled.

AI Number 2 Provide final Qwest position on policy and contract implications: Remains open. As discussed when this action item was opened, it cannot be closed until February at the earliest.

12/13/01 December CMP discussion: Alan reviewed Qwest response and advised that he is still having discussions with legal to determine if Qwest can proceed with this request. Alan will provide an update at the January CMP meeting. A preliminary update will be sent to the CLEC Community for distribution to their legal departments prior to the January CMP meeting.

FROM PC100101-2 This e-mail below from SBC. It provides responses to questions raised in the clarification meeting held on 29-Oct-01.

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

DRAFT RESPONSE For Review by CLEC Community and Discussion in the December CMP Meeting

This letter 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