Billing Q & A with Jim O’Neill

Dear Readers – In the October 2002 column, we wrote about reciprocal compensation agreements. A service provider had written in, asking for information sources, standards, regulations or related practices that would eliminate double billing and other related issues. The fact is reciprocal compensation is a complicated and there are many ways of dealing with this constantly evolving issue. With that being said, after publication of the October issue, I received the following (slightly edited) response from Darold Coffey, a systems analyst at Sierra Telephone in Oakhurst, California. In Mr. Coffey’s response he notes that the Terminating Point Master is evolving to have thousand block pooling information in the main table for all of North America. He also explores various ways to identify other carriers who are sending information to a switch by using the line level indicator of offices that have been set up for portability.

Mr. Coffey writes:

A—I read your October 2002 column in Billing World with great interest. I don’t proclaim to be an expert on the subject, but some thoughts came to mind, and I certainly welcome enlightenment on this subject.

The TPM (Terminating Point Master) has TBP (Thousand Block Pooling) information in it, in a separate table from the usual TPM information. There are currently 2 tables to get everything you need, but in a few months there will be one TBP table for all of the NANP (North American Numbering Plan). It will have NPX-NXX-L level information, including all of the same information that was in the TPM table. I use these as a source for OCN (Operating Company Number) lookups. Last time I looked, the required level of information is not available in the LERG (Local Exchange Routing Guide).

As pointed out in your article, Carrier Access Billing (CABS) is based on agreements between the carriers, so anything can happen (or not) if that is what the parties want. However, I think a somewhat generic model might look like this:

For billing the proper OCN for a call, I think you should be able to use the originating LRN (Location Routing Number) to get the OCN for the (direct route to your office) switch that originated the call. I believe switches that have number portability should have this set up. If an LRN is not available, use the originating number NPA-NXX-L. The assumption is that because the LRN is not available, both the number and the originating switch are not set up for portability.

The terminating recording switch will need to have Module 718, 719 or 720 turned on for the desired trunks. There is some additional code needed in downstream billing programs, but that should not be a significant problem for the billing department, if you work with them ahead of time.

For wire calls, if you have the originating number NPA-NXX-L and the LRN from the originating (direct route to your office) switch, you should have enough information to determine the OCN for that call. If the originating number has not been ported, the originating NPA-NXX-L OCN should be the same as the originating LRN OCN, so it does not matter which one you use. Now, the originating switch LRN OCN and originating phone number OCN may not be same. But think about it—if the number is ported, you would not want to bill the originating number OCN (where the number was ported from), would you? You would want to bill the company that the number was ported to—which should be the originating switch owner.

For a cell number that is roaming or for any number that has been ported, the same concept and mechanism would apply, since the originating number owner is not directly involved with the specific call. Only the company that owns the switch just before the call came to you has anything to do with transporting that leg of the call to you.

If the originating switch owner wants to do his own form of access billing for ported or roaming calls that pass through his switch, so be it. That is between him and the owner of the originating number or the switch that brought the call to him. The terminating carrier has nothing to do with that. All the terminating carrier sees is the originating number, and maybe the originating LRN.

This mechanism will also serve the situations where small blocks of numbers (less than 1,000) have been assigned to local needs from wire-based carriers to pagers, CLECS or cell service. The originating switch must provide an LRN if it is ported, and it must be recorded by the terminating carrier.

Pagers and distinctive ring/Secondary Directory Numbers (SDN) can’t originate calls, so it doesn’t matter what the originating OCN is. A terminating carrier interested in billing for calls to a pager or SDN number would already know the OCN for those terminating numbers.

Fax numbers are just like other voice numbers, so treat them that way. The same applies to resale and unbundling; bill to the originating (direct route) switch owner. That operating company can do its own pass-through billing, if it wants to.

The only problem I have found with this is that sometimes (actually rarely) a switch LRN or a cell phone originating number can lag behind an area code split permissive dialing. These calls may fall out for a while, but eventually they get fixed too.

Another thought comes to mind: Will switches someday need to do more with their LRNs than have 0000 or 9999 in the LRN-LLLL? The LLLL in an LRN might be set to identify a specific switch within a company. I have not seen any trouble with this yet.

I can’t see any reason for double billing, except for a company that is not billing to the right OCN, or if a company is creating two billing records, one for the originating switch owner using the LRN OCN, and another for the originating number OCN. Neither of these scenarios should happen.

With this in mind, why would it be necessary to have an NPA-NXX-LLLL database? Sounds like it would be expensive and a nuisance to maintain.

I am not sure that Mr. Coffey’s comments are the final answer to these problems, but they clearly have value. Let’ keep this discussion going as long as necessary to get some clarity. Any and all comments are welcome if they help clear the air on these issues. -- Jim