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May 26, 2009
Kicking the Tires
It’s a good idea to get into the habit of checking the vendor’s tariff before issuing a claim--and not just as a matter of dotting I’s and crossing T’s. The last thing you’d want to do is hamstring the negotiation process by shortchanging your own claim. It may be helpful to think of a potential dispute as a pending transaction at a used car lot: both sides want the car to sell, but the issue is on whose terms. Getting all the facts lined up before letting the salesman know how much you are willing to spend is simply prudent car shopping.
Perhaps a PIU audit shows that a company is not properly applying a default factor. Industry standard may say that 50% is the usual default. However, if the company’s own tariff provides a different default, perhaps even 75%, then the difference can amount to a sizable increase in the potential savings. If a rate benchmarking audit yields a company charging excessively, that’s a good start. Sometimes though, the vendor just isn’t even billing their own tariffed rate. Here again, taking the time to check the tariff and getting the dispute right in the first place is much easier than trying to negotiate a settlement while you are at the same time trying to increase the amount in dispute.
In an ideal world, there would be no need for this kind of scrutiny. In an ideal world, everyone would forthrightly share all of the various components that comprise inter-carrier billing. However, given the gap between the world we live in and that ideal, it always makes sense to leave no stone unturned during the dispute preparation stage. If you have to open the bidding on a used car, better make that initial offer in your best interest. Otherwise you are just bidding against yourself.
Posted in at 04:37 PM | Permalink | Comments (0) | TrackBack (0)
May 18, 2009
CLEC Rate Caps
Many states and the FCC have ordered CLECs to cap their switched access rates no higher than the incumbent local exchange carrier (ILEC). There have been many disputes against CLEC CCL charges, since few of the ILECs continue to charge CCL. The CLECs argue that they are not required to maintain the same rate structure as the ILECs and they only need to meet the rate requirement with a “composite” rate.
This is supported by the FCC CFR § 61.26 Tariffing of competitive interstate switched exchange access services.
(5) The rate for interstate switched exchange access services shall mean the composite, per-minute rate for these services, including all applicable fixed and traffic-sensitive charges.
Technologies Management Inc. (TMI) also provides composite benchmark rates for the ILECs. Their calculations include charges for circuits to tandems and for direct end office circuits converted to a per-minute of use charge. Typically carriers pay for these circuits on facilities invoices, so these charges should be removed from the TMI benchmark rates.
Posted in at 12:20 PM | Permalink | Comments (0) | TrackBack (0)
May 06, 2009
No Tip for Extra BIP
The majority of telecom analysts have a working knowledge of what BIP is. However, in the event that you are new to the telecom industry, here is a brief overview. BIP, which stands for Billing Interconnection Percentage, is a billing arrangement that applies when two or more LECs in the same LATA are used to complete a call or private line circuit. This charge pertains to transport rate elements, therefore many analysts verify BIP when performing channel mileage audits. It is always a good idea to verify BIP on high-mileage and high-rate circuits.
Occasionally, a carrier will not only charge the wrong BIP, but also charge another carrier’s BIP. The result: your carrier could be the one getting double-billed.
Example: Let’s say you are performing an audit on behalf of a Client. The Client completes a call/line and requires the resources of two additional carriers, Carrier A and Carrier B. Carrier A bills the Client for the correct BIP. However, Carrier B charges the Client for its respective BIP and the BIP of Carrier A. Confirm any suspicions of wrongful billing by requesting CSRs from both carriers. The CSRs will serve as proof of incorrect charges if a dispute arises. Investigate how long these charges have billed incorrectly and you might have a lucrative claim for your client.
Posted in Audit at 03:03 PM | Permalink | Comments (0) | TrackBack (0)
May 05, 2009
You Catch More Flies with Honey – an Approach to Vendor Interaction
Dealing with vendors can be a hassle, or it can be a pleasurable experience. All in all, a billing analyst’s perspective concerning vendor interaction has to do with their approach to problem solving, human interaction, and conflict. One can either be positive, helpful, and pleasant with a vendor, or negative, defensive, and cold. I have felt and attempted both types of interaction. Each type yields its own result but, in the end I learned, you catch more flies with honey.
I used to fear the vendor. When the phone rang I would stare at it, allowing it to ring 2 or 3 times before hesitantly picking up the phone. Is this someone calling to yell at me? Will they call with a problem that I can not solve? Over time, as I learned more about telecom and became comfortable with the daily business process and software, I grew comfortable in my conversations with vendors and tackling problems. Overcoming this first challenge was not winning the war; it was only half the battle.
I found myself taking a negative tone when speaking with vendors concerning dispute dollars. I was looking at the vendor as my enemy rather than a person who wants to resolve the issue and move on with their day. It is my belief that I learned this approach from vendors I spoke with on the phone who treated me in a similar manner. It felt necessary to be on the defensive at all times. I was taking my job personally, and began to realize this was hurting my performance in dispute resolution. I came to realize that whether an analyst is right or wrong concerning disputes, no one wants to help someone that they feel is attacking or speaking down to them. I came to re-learn a 1st grade lesson that has stood the test of time; just because other people act a certain way, does not make it right.
Currently, I work hard to be proactive when I see a problem, picking up the phone and calling the vendor to let them know of an issue before they discover it. Attempting to help the vendor resolve issues, even when the issue begins on their end, helps create a positive working relationship. In general I am pleasant, positive, and knowledgeable. I believe this new perspective helped me to gain strong working relationships with vendors, in turn strengthening the client’s relationship with the vendor. Equally as important, this approach allows for smooth and quick dispute resolution. In the end, you really do catch more flies with honey.
Posted in Training at 11:47 AM | Permalink | Comments (0) | TrackBack (0)
May 01, 2009
How do you connect?
Circuits interface to locations in various capacities. Some of the levels which a circuit can interface at are OC, DS3, DS1, DS0, and collocated level. The level of the interface determines what types of charges can be billed. The NCI (Network Channel Interface) code indicates at what level the circuit interfaces. If a DS1 has a DS3 for a CFA, then at those locations of the DS3, the DS1 would have an NCI code equivalent to that of a DS3. Get to know your NCI codes. They will help you spot errors in your billing.
Posted in at 03:22 PM | Permalink | Comments (0) | TrackBack (0)
Recovery of Charges Over 2 Years
Are carriers seeking to recover charges for services not previously billed or collected? Revenue assurance teams are actively looking for unbilled and uncollected costs in an effort to boost revenue, cash, and profit. In several cases, we have seen carriers seek to recover money beyond the statute of limitations. If you do not already have a superseding agreement (I.e. an Interconnection Agreement with a stake agreement clause), then the carrier may only collect up to 24 months per the Communications of 1934.
Following is a link to the complete act, as well as an excerpt from section 415 which contains the statute of limitations:
http://www.fcc.gov/Reports/1934new.pdf
Communications Act of 1934
SEC. 415. [47 U.S.C. 415] LIMITATIONS AS TO ACTIONS.(a) All actions at law by carriers for recovery of their lawful charges, or any
part thereof, shall be begun, within two years from the time the cause of action
accrues, and not after.(b) All complaints against carriers for the recovery of damages not based
on overcharges shall be filed with the Commission within two years from the time
the cause of action accrues, and not after, subject to subsection (d) of this section.(c) For recovery of overcharges action at law shall be begun or complaint
filed with the Commission against carriers within two years from the time the
cause of action accrues, and not after, subject to subsection (d) of this section,
except that if claim for the overcharge has been presented in writing to the carrier
within the two-year period of limitation said period shall be extended to include
two years from the time notice in writing is given by the carrier to the claimant of
disallowance of the claim, or any part or parts thereof, specified in the notice.(d) If on or before expiration of the period of limitation in subsection (b) or
(c) a carrier begins action under subsection (a) for recovery of lawful charges in
respect of the same service, or, without beginning action, collects charges in
respect of that service, said period of limitation shall be extended to include ninety
days from the time such action is begun or such charges are collected by the
carrier.(e) The cause of action in respect of the transmission of a message shall,
for the purposes of this section, be deemed to accrue upon delivery or tender of
delivery thereof by the carrier, and not after.(f) A petition for the enforcement of an order of the Commission for the
payment of money shall be filed in the district court or the State court within one
year from the date of the order, and not after.(g) The term ''overcharges'' as used in this section shall be deemed to mean
charges for services in excess of those applicable thereto under the schedules of
charges lawfully on file with the Commission.
Posted in Audit at 01:36 PM | Permalink | Comments (0) | TrackBack (0)
Sometimes it’s not NECA
John Staurulakis, Inc. – Tariff FCC No.1
Some smaller carriers do not use NECA 5 to concur in for interstate access; the other alternative is the John Staurulakis, Inc. Tariff FCC No.1. Below is a list of carriers that use the JSI tariff.
Atlantic Telephone Membership Corporation; Bluffton Telephone Company, Inc.; Fort Mill Telephone Company; Farmers Telephone Cooperative, Inc; Hargray Telephone Company, Inc; Home Telephone Company; Horry Telephone Cooperative, Inc; Interstate Telephone Company; Lancaster Telephone Company; Mt. Horeb Telephone Company; Millington Telephone Company, Inc.; Pineland Telephone Cooperative, Inc.; Rock Hill Telephone Company; Smart City Telecommunications LLC d/b/a Smart City Telecom; Star Telephone Membership Corporation; South Central Rural Telephone Cooperative; TDS Telecom Companies; Chesnee Telephone Company; Gearheart Communications Company; Skyline Telephone Membership Corporation; Yadkin Valley Telephone Membership Corporation.
The rates are in Section 17 and contain all the interstate rates with several exceptions.
1) End User Access Service and Federal Universal Service Charge (FUSC). For these two services, you can reference the NECA 5 tariff. 2) The carrier - Interstate Telephone Company does list the End User Access Service and FUSC rates in the JSI tariff.
Posted in at 11:43 AM | Permalink | Comments (0) | TrackBack (0)
