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Breaking Down the FCC Order: VoIP-PSTN billing

This blog is an update to an earlier blog titled VoIP is Access Billable.

In the FCC USF/ICC Reform Order that will be effective December 29, 2011 (assuming there are no requests for reconsideration and appeal), under Section XIV., titled Intercarrier Compensation for VoIP Traffic, paragraph 933 says, “Default intercarrier compensation rates for toll VoIP-PSTN traffic are equal to interstate access rates.”

Today, there is no means to determine actual VoIP traffic from non-VoIP traffic.  In the industry standard Exchange Message Interface (EMI) records, there are indicators with a specific value to identify IP-Originated or IP-Terminated usage. However, since there is no means to determine actual VoIP traffic, these indicators are not able to be populated correctly and thus prove to be unreliable.

The Order does recognize the limitations of determining actual VoIP traffic.  The Order says, “carriers today supplement call detail information as appropriate with the use of jurisdictional factors or the like when the jurisdiction of traffic cannot otherwise be determined.  We find this approach appropriate here, as well.”

Intrastate tariffs that have already been filed for VoIP-PSTN traffic have language regarding a Percent VoIP Usage (PVU) factor.  This factor is used to separate originating and terminating intrastate VoIP Minutes Of Use (MOU) from non-VoIP MOU.  Once VoIP MOU are determined, they are billed against the VoIP-PSTN rates identified in the intrastate tariff which, by the Order, are equal to the interstate access rates.

For Data Center clients: NISC will need to receive your revised intrastate tariff pages for VoIP-PSTN traffic.  We do not need your entire intrastate tariff, only the revised pages. NISC will also need to receive all PVU factors reported by your access customers.  Only those access customers that provide PVU factors will see the separation of the MOU and the billing of VoIP MOU at rates equal to interstate access rates.

NISC is making software changes for VoIP-PSTN traffic.  We plan to have these changes in place for usage dated December 29, 2011 and forward.

The industry has not had time to prepare for PVU factors.  For access customers that provide PVU factors, in the intrastate “Details of Statistics” section of the CABs bills, a factor known as Percent Internet Bound Traffic (PIBT) will be used to store the PVU factor until industry changes can be made.  For each traffic type, MOU will be separated for VoIP and non-VoIP based on the PVU factor.  In the intrastate “Details of Usage Charges” section, all rate elements will show MOU at existing intrastate rates (representing non-VoIP MOU) and MOU at rates equal to interstate access rates (representing VoIP-PSTN MOU).