*** Ken Babcock will be hosting a free webinar on the new rules and impacts of the Rural Call Completion order on Wednesday, May 23, 2018 at 1 PM EST. Click Here to sign up for the webinar ***
Changes are here for Rural Call Completion reporting and compliance. The good news is that the FCC has ruled in FCC18-45 that, effective immediately, Covered Providers no longer must submit FCC 480 – Rural Call Completion Reports to the FCC on a quarterly basis. Thus, the report that was due May 15, 2018 covering the 1st Quarter, 2018 does not have to be submitted.
However, there are new and increased FCC regulations as spelled out in the Second Rural Completion Order that was published in the Federal Register on May 10, 2018 and that goes into effect on June 11, 2018. Covered Providers, as defined in the previous Rural Call Completion Report regime, must now implement an internal contract management and monitoring process that is far more stringent than anything experienced previously.
Part of the impetus for the new FCC ruling is the Rural Quality and Reliability Act that was signed into law by President Trump on February 26, 2018.
“This law will increase the reliability of Intermediate Providers by bringing transparency and standards to the market. The FCC has been charged with creating these standards within 180 days (August 27, 2018).”
Now, the FCC in its most recent ruling has ordered Covered Providers to measure answer rates and call completion rates at the Intermediate Provider level. The Intermediate Provider is defined as follows:
“Intermediate Providers” are third party carriers hired by long distance providers to route and deliver calls to local telephone providers serving rural areas.
In my terms, the Intermediate Provider is today’s Interexchange Carrier (IXC ) that primarily performs interLATA call transport and call completion services. So, the focus for determining the reliability of telephone call completion services in rural markets is shifted from a corporate view across all Intermediate Providers to a much more detailed view at the individual Intermediate Provider level.
For one customer that I supported in preparing the previous type of Rural Call Completion reports, the new FCC order translates to at least five (5) times the amount of work that I had to perform. Basically, there would be a need to be on top of answer and call completion rates for each of the IXCs that had been contracted with to perform transport and call completion services for Long Distance (LD) calls routed to the domestic US market.
While no actual report must be documented and sent to the FCC, each Covered Provider must have a total grasp on exactly how each of its contracted Intermediate Provider is serving the rural Incumbent Local Exchange Carriers (ILECs), the non-Rural ILECs and now the rural Competitive Local Exchange Carriers (CLECs) as well.
The FCC is clearly putting the burden of defining and measuring metrics on the Covered Provider. The Covered Provider is expected to put teeth in the contracts it negotiates and implements with each Intermediate Provider to ensure reliable service to all customers regardless of where they reside.
If not, and it turns out there are bona fide rural ILEC and/or CLEC customer complaints, the FCC will come knocking and to the extent there is no record of the affected Covered Provider having been doing its job in monitoring and enforcing quality standards with its Intermediate Providers, then financial penalties such as the multi-million dollar plus fines levied on Verizon and T-Mobile USA in the past will not be out of the question.
Clearly, there is still a need to record and store a minimum of six (6) months of interstate and intrastate interLATA Call detail records (CDRs).
These call details must be utilized to accumulate, summarize and publish internal measurements at the Intermediate Provider level. This information must be available at both the prospective as well as retrospective level.
Following are the most salient features of the new FCC order:
- All Intermediate Providers must be registered with the FCC.
- Each Covered Provider must have a clear record of each registered Intermediate Provider it utilizes.
- Each Intermediate Provider must have a documented record of which additional Intermediate Provider it employs to perform call completion functions to the ILEC and CLEC markets. The intent here is to limit the number of Intermediate Carriers utilized in completing any one call. This is referred to as limiting the number of “hops” on any one call.
- Intermediate Providers who hand-off LD calls to other Intermediate Providers must have the same level of documentation as Covered Providers on answer and call completion rates to rural and non-Rural domestic US markets.
- Each Covered Provider must show a record of enforcement and removal, if necessary, of any Intermediate Provider that fails to perform as expected and as defined in its contracts with Intermediate Providers.
- NECA has been identified as the entity to which the rural CLECs must identify themselves.
- NECA will continue to be the source for both rural and non-rural ILEC identification by Operating Company Number (OCN).
- Each Covered Provider must have current Rural Call Completion contact information to be used by rural CLECs and ILECs to report and resolve call completion complaints.
Overall, there is nothing to feel comfortable about in the new order.
While there may be softening of the FCC stance over time in future orders, there is no guarantee that a softening will occur in the very near future.
In the meantime, each Covered Provider needs to have its environment under control and there may be a good and sufficient reason to consider the services of third party providers experienced in implementing and maintaining large-scale data warehousing and associated report processing to take the obvious sting out of what surely is facing the Covered Providers and Intermediate Providers as an immediate obstacle.
So, while there is definitely some good news, the Second Rural Completion Order will not help any Covered Provider or Intermediate Provider sleep better at night in the short term.