The Federal Communications Commission (FCC) has recently published an Order that impacts all U.S. Service Providers offering long-distance services to rural markets. The Rural Call Completion (RCC) Order was created to help the FCC better monitor call quality to rural areas, which has suffered from carriers intentionally obstructing long distance calls to rural subscribers, even to the point of creating ‘false ring signals’ where the caller hears the phone ring, but the phone never actually rings on the receiving end and the call never goes through. It is believed that some long distance carriers are guilty of this deceptive tactic in order to avoid paying high call completion rates to the terminating carrier.
While the Order is not yet approved, the FCC has already laid out the reporting and data retention requirements and it seems straightforward enough. But is that really all there is to it? Are you a ‘Wireless Operator’? Do you need to be concerned with the originating point of the call? Does Local Number Portability matter? These are just some of the additional questions you need to be asking yourself in order to comply with these new rules.
Background:
Rural consumers have been reporting problems in receiving long distance or wireless calls on their landline telephones. Consumers calling or living in these rural areas are being encouraged to report call completions problems to the FCC. Complaint volumes have been significant and therefore, the FCC has adopted new rules and is requiring “Covered Providers” to report on metrics that track and identify call completion percentages to both Rural and Non-Rural Carriers.
Data Requirements:
The FCC has clearly laid out the data retention (and reporting) requirements to comply with the order. For data retention, the following information for calls to Rural OCNs must be kept for a minimum of six months:
- calling party number
- called party number
- date
- time
- an indication whether the call attempt was handed off to an intermediate provider or not and, if so, which intermediate provider
- the rural OCN associated with the called party number
- an indication whether the call attempt was interstate or intrastate
- an indication whether the call attempt was answered, which may take the form of an SS7 signaling cause code or SIP signaling message code associated with each call attempt; and
- an indication whether the call attempt was completed to the incumbent local exchange carrier but signaled as busy, ring no answer, or unassigned number. This indication may take the form of an SS7 signaling cause code or SIP signaling message code associated with each call attempt.
In addition, monthly reporting (at the OCN level for Rural OCNs and at the aggregate for Non-Rural OCNs), is required to be submitted on a quarterly basis.
What are the Pitfalls?
While the overall data retention and reporting requirements seem straightforward, it’s important to watch out for the “gotchas”. Where do I get this information and how will I store all this data for future reporting? How does Local Number Portability (LNP) impact my reporting? What if I’m a wireless carrier – what do I need to know about the Originating Point of the call? How about the Jurisdiction? What does Long Distance mean? Is it just IXC Trunk Groups?... or perhaps even that is too ambiguous. How do I know if I even need to comply with this reporting – am I a “Covered Provider”?
Local Number Portability impacts the operating company number (OCN) of the called party, which impacts both rural OCN reporting and data retention requirements. The originating point of a wireless caller is always a topic of discussion. Should the Originating Cell Site be used as the origination point, or what happens if the switch handled the call, or even the originating NPA-NXX? Roaming also impacts wireless carriers, so as I mentioned earlier, determining the true originating point of the call is not always so simple. In all of these cases, the jurisdiction (Intra- or Interstate) is also in question.
To add to the confusion, how do we define “long distance” calls – are they simply those that traverse an IXC provider’s network? Networks are in constant flux and carriers are using multiple sources to deliver their calls. Alternative providers, IP networks and even direct connections between providers for services, may impact your analysis.
When designing a solution to meet these FCC requirements, it is not only important to have the ability to properly decipher the call records in order to provide the required reporting data (which in and of itself is not a trivial matter) but it’s also important to understand the underlying meaning of the data in the records and your own network topography. It is also essential for your reporting solution to be flexible enough to meet future needs if the FCC offers more insight into some of these questions as they start collecting and analyzing the reports. And finally, access to the underlying data will also become important as new questions are raised during the reporting process.
This article was first published in Fierce Telecom. You can find the original version here.
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