Most audits starts with a change in the trend of the billing. This is the first problem with identifying a removed CIC. The billing trend may not change and the error in billing could continue indefinitely. The second problem is that some companies rely on manual updates to a spreadsheet or word document to track CIC changes. This is helpful, but manual updates always leave room for mistakes.

The best way to catch an error is for the CIC to be populated in a detail Switch Data database. An auditor can run various reports to trend the CIC traffic. By creating monthly reports, the auditor can identify the issue quickly, ensure that the CICs have been removed from your billing, and increase the chances of getting full credit from the vendor.

Some vendors, like Qwest, have some of their USOCs broken down based on the term plan. For example, the 3 in FJCP3 denotes a 3 year plan while FJCP5 is a 5 year plan USOC. These are simple to figure out and don’t require much additional effort, making it easy to look for errors such as an incorrectly applied term plan rate.

However, vendors such as Pacific Bell and Southern New England Telephone can sometimes use summary USOCs. These USOCs are what show the amounts actually being billed, and can be composed of a single charge, or a combination of charges. The typical summary USOC for Pac Bell is P5FAS, and for SNET it is 1ZZPZ. These USOCs commonly combine channel terminations, muxes, and mileage, as well as other charges.

The reason these need to be understood is that they do not always have to combine all the charges on a circuit. They will always be listed on the CSR whether they are billing from the summary USOC or on their own. As a result, it is important to check these summary USOCs in conjunction with the USOCs they summarize, as double billing or the application of incorrect rates can occur.

Knowing the way your vendor’s system works allows you to figure out common errors in that system, which produces faster dispute findings and more savings.

In some cases, claims may be denied due to a lack of supporting evidence. You may not be explicitly told what documentation is needed, but it is your responsibility to make sure claims are not closed prematurely. Due to overwhelming volume, many large vendors today load disputes into their system where it is stripped of all but the most pertinent information. Therefore, if you submit a claim via email with supporting documentation attached, that supporting evidence is not guaranteed to reach the analyst reviewing the dispute.

Fortunately, nearly all vendors have a re-dispute process in place for denied claims. The process, as well as the window of opportunity to submit a follow up will vary between vendors. Therefore it is critical to maintain records of denials received and stay updated on the time remaining before claims will be closed. When filing a re-dispute, be sure to include the following items.
1. Claim number of previous dispute – If the original dispute was assigned a vendor claim number or file ID, include this information, it will be helpful in the long run.
2. Re-dispute amount claimed – Pending your review of a resolution, this may or may not vary from the original amount disputed. Provide this information at a USOC or circuit level whenever possible.
3. Re-dispute reason – The most important part of a re-dispute needs to be more than restating the original claim description. Supply specific information/tariffs/examples to refute the denial resolution received by the vendor.
4. Supporting documentation – If additional evidence was originally provided, it is a good idea to include this with all re-disputes to ensure the information is received and reviewed.

If a claim continues to be denied and your research validates your position, continue to re-dispute your position until you are satisfied with the response. A request to escalate a claim may be appropriate for certain items, but there is also no shame in admitting a mistake and closing an issue as a loss. Lastly, it is important to understand that the claim and re-dispute process is not always cut and dry. Negotiations between vendors and customers are ongoing, and disputes may be used as leverage for future savings, deals, or business opportunities.

Where should you look when the tariff you need is for a smaller, independent company? A good place to check first is the PUC website for the state you need. Some PUC and PSCs maintain a good tariff database online where tariffs can be searched for by company name, type of tariff, etc. The Ohio PUC and the Arkansas PSC are just two examples of state regulatory commissions that provide an online database of searchable state tariffs.

While not every state utility commission provides an easily searchable database of tariffs, it is usually a good place to start when you are looking for that intrastate tariff that is seemingly impossible to find.

Most term plans require customers to pay back a portion of the monthly recurring charges remaining under a commitment. So the sooner a circuit is disconnected, the lower the overall charges that are paid on that circuit. However, with term plans that are structured with penalties that are calculated as a payback of savings, the early termination liability on a circuit grows over time as the savings increases, often to amounts that are larger than the total of the recurring charges would be if the circuit were not disconnected until after the commitment term expires. It therefore becomes very important for groups that are in charge of issuing disconnect orders to be aware of the potential early termination penalties on circuits and to understand how those penalties will change if the disconnect order is delayed.

When auditing early termination penalty charges it is amazing how large these charges can become and how much of them can be avoided by delaying a disconnect order by a few days or months. In one extreme case I found term penalty charges of over $100K that could have been entirely avoided if the disconnect order had been submitted just three days later. Often a delay of a few months will shift penalties into another tier, greatly reducing the amount owed.

It pays to be aware of existing term commitments on circuits and understand how the early termination penalty structure can best be managed when disconnecting or rehoming circuits.

Company Info: Telstra is an Australian telecommunications and media company, formerly owned by the Australian government and privatized in stages from the late 1990s. Telstra is the largest provider of both local and long distance telephone services, mobile services, dialup, wireless, DSL and cable internet access in Australia. Telstra Wholesale provides products such as Data, Mobile, Voice, and other Facilities (including Colocation and Duct Access) to other companies and organizations for re-sale. Telstra Wholesale also provides operational support for its customers, and facilities for international customers such as International Data Transport and IP Transport. Here is Telstra website: http://www.telstra.com.au/homepage/d2/index.html.

Access to Invoices: Telstra has E-billing system. So instead of asking your client to supply you with copies of invoices, ask them to provide you with Digital Certificate. This certificate will allow you to access Telstra billing website directly and view/download all data necessary for the audit.

Tariffs/Contracts: Telstra publishes their tariff on its website. It is called “Our Customer Terms”(http://www.telstra.com.au/customerterms/bus_government.htm). In addition your client and Telstra might have CRAs (Customer Relationship Agreements) in place. These CRAs contain regular and discounted pricing lists for services not covered by OCT.

Claims Submission: Telstra requires claims to be submitted on its claim form and will not accept any other format. Make sure you request this claim form from your client. All disputes need to be sent at the following address: Carrier.Disputes.Team@team.telstra.com. You will receive an acknowledgment within the next few days. It takes about two months for Telstra to work your dispute and advise you on resolution.

Good Luck!

Backbilling in excess of two years – It is standard practice in the telecom industry that carriers backbill for unbilled or incorrect charges for no more than two years. As stated in an earlier blog post, this is provisioned by the FCC Act of 1934 in Section 415. Smaller carriers in particular will occasionally backbill more than two years.

Changes in MRCs – From time to time, carriers will adjust the MRCs and provide credit in the OC&C. For example, let’s say a carrier was overbilling mileage on a circuit because the incorrect rate was applied. It’s a good idea to research how much credit was issued. The carrier may have only given credit for one month when your client is actually due credit for 24 months.

Installation and ETLs – Be sure to investigate high-dollar installations and early termination liabilities. You can recover overbilled charges on installs by verifying what was ordered on the ASR and the ASR due dates. The same applies for disconnects and regrooms when ETLs apply. Check the disconnect or regroom dates as well as the term agreement start/end dates as well.

Digital Main Switching Units (DMSUs)
There are currently 76 DMSUs in use. These are the original long distance exchanges and each DMSU has the capacity to handle 30,000 calls at any one time. Every DMSU has a connection to every other DMSU within the network.

DMSUs are named after their location as well as a local theme. Examples of DMSU names include Edinburgh Bruce (named after the infamous king of Scotland Robert Bruce), Nottingham Arrow (an acknowledgment of the Robin Hood legend) and Shrewsbury Darwin (Shrewsbury was the birth place of Charles Darwin).

Wide Area Tandems (WATs)
There are currently 16 WATs in use in the UK. As opposed to the long distance calls routed through the DMSUs, the WATs are used to connect calls within a particular region. While a WAT might be connected to the DM Network (and DMSUs) via a connection or two, they are not connected to all of the DMSUs or even all of the WATs. They route their calls from one Digital Local Exchange (DLE) to another DLE within the same region.

Similar to DMSUs, the WATs are named after a local theme. For instance one of the WATs is named Reading White Knights, after White Knights Park - home to the University of Reading (the park itself was named after 13th century knight John De Erleigh IV who was otherwise known as the “White Knight”) and the WAT in Liverpool is named the Liverpool Cavern after the famous Cavern Club where Brian Epstein first heard the Beatles play.

Digital Junction Switching Units (DJSUs)
There are 13 DSJUs in use. DSJUs are additional switches within the area of London that allow regional London traffic to be routed from one DLE to another. This saves on the capacity of the DMSU and WAT network. Essentially DSJUs are a tandem network within a tandem network that just serves the London area.

Unfortunately, DJSUs are named only after their location within London, so their names are a little less evocative – such as North Paddington A.

Next Generation Switches (NGSs)
There are currently 63 NGSs being used within the DM Network. These are newer digital switches capable of routing both regional and long distance calls and they are being gradually deployed to replace the aging DMSUs and WATs that have reached their capacity and usefulness. Depending on how it is configured an NGS can handle anywhere from 60,000 to 120,000 simultaneous calls.

NGSs are named after minerals, precious metals, stones, etc. Examples of NGS names are Leicester Opal, London Topaz and Edinburgh Ruby.

Advanced Services Units (ASUs)
In addition to the four types of tandem switches listed above, there is another set of switches used to handle additional services like FeatureNet (a BT product that offers a portfolio of VPN services). These switches are known as ASUs and there are currently 26 of them in use.

ASUs are named after mythological creatures or astronomical features. Examples of ASU names are Leeds Atlas, Leicester Pluto and Guildford Venus.

Cost management tip: It is a good idea to do a periodical inventory review of leased circuits associated with the COW sites. While some COWs are being used for an extended period of time, others are just a one time deal, a temporary solution. Disconnect leased facilities where COW is no longer needed.

So count your COWs. Maybe some of them already left your pastures.

So, what does this mean?

As part of the rulings, a CLEC is required to “mirror” the rates of the dominant incumbent local exchange carrier (ILEC) for interstate switched access. Most often, this is one of the regional bell operating companies (RBOCs). The FCC carved out a set of criteria by which a CLEC could exceed the ILEC rate. Specifically, if the CLEC competed with a non-rural ILEC and served only customers from areas with a population less than 50,000, then it was afforded the ability to charge the highest banded rate from NECA FCC No. 5. The next logical step in the progression here, then, is traffic pumping migrated to CLECs whose service area illustrated they served only rural geographic areas. Thus, these CLECs could theoretically gain the benefit of the higher switched access rates and the high volumes of traffic associated with traffic pumping.