ARCHIVED -  Telecom Order CRTC 96-1592

Telecom Order

Ottawa, 23 December 1996

Telecom Order CRTC 96-1592

IN THE MATTER OF an application by Call For Less dated 13 November 1995, for contribution exemption for a Centrex system in the Toronto (416) 365 exchange, used for both single-hop and double-hop services.

Reference: 95-1284

WHEREAS Call For Less enclosed an affidavit dated 14 November 1995;

WHEREAS by letter dated 13 December 1995, Bell Canada (Bell) noted that while separate virtual facilities group (VFG) are provided for this system, it does not control the classification or the routing of calls to each VFG;

WHEREAS accordingly, Bell submitted that, as with similar applications by other resellers, a technical audit is required to verify the accuracy of the routing of calls;

WHEREAS by letter dated 20 February 1996 (enclosing an affidavit dated 20 February 1996), Call For Less applied for an additional exemption for a Centrex system in the Oshawa (905) 404 exchange;

WHEREAS Call For Less noted that this submission supersedes its application dated 13 November 1995;

WHEREAS by letter dated 27 March 1996, Bell noted Call For Less' statement that the Oshawa Centrex system is configured with three VFGs and is used to provide both single-hop and double-hop calling, as well as service for administrative use;

WHEREAS Bell confirmed that it controls the routing of calls to each VFG and was able to verify that the service arrangements are as described, and that calls are correctly routed so that contribution charges are applied to interexchange calls;

WHEREAS therefore, Bell agreed with the requested exemption for the Oshawa system;

WHEREAS Bell reaffirmed the need for a technical audit for the Toronto system, further noting that the service configurations at the Toronto and Oshawa locations are different, and that it is not able to verify the service configuration in Toronto;

WHEREAS Bell submitted that the application dated 20 February 1996 for the Oshawa system is unrelated to, and cannot supersede the previous application with respect to the Toronto system;

WHEREAS by letter dated 17 May 1996, Call For Less submitted a technical audit dated 14 May 1996 for the Toronto Centrex system in the (416) 365 exchange;

WHEREAS by letter dated 31 July 1996, Bell provided comments with respect to the Toronto system technical audit;

WHEREAS Bell noted that the decision as to whether a customer's number should be assigned, an exempt or a contribution-bearing status is made manually and then programmed into the system;

WHEREAS Bell submitted that in this respect, the assignment does not appear to be subject to pre-defined controls since the auditor has noted that at least two errors in assignment of classification existed in the database at the time of the audit;

WHEREAS Bell also noted that no clear basis has been provided for the auditor's conclusion that call-back services identified are correctly classified as exempt;

WHEREAS Bell submitted that approval should be granted only after Call For Less has satisfied the Commission that a documented auditable control procedure for assigning and verifying a Class of Service Code is in place;

WHEREAS by letter dated 16 August 1996, Call For Less filed clarifications to its audit report of 14 May 1996;

WHEREAS Call For Less stated that a manual procedure for assigning and verifying the Class of Service Code has been developed and is in place;

WHEREAS Call For Less stated that it will periodically verify with Bell to ensure that any changes are identified;

WHEREAS by letter dated 5 September 1996, Bell submitted that although the new control procedure outlined by Call For Less in its 16 August 1996 submission serves to provide a further check of the Call For Less configuration, it does not satisfy the requirement to verify the configuration on an ongoing basis;

WHEREAS Bell submitted that there is a requirement for a control procedure to ensure that the initial Class of Service assignments remains unaltered, and to verify that the routing of calls within the Centrex system over contribution-exempt and contribution-bearing VFG remains unchanged over time;

WHEREAS Bell noted that in other similar instances, resellers have initiated internal procedures to record such activity and to provide a convenient audit trail should there be a requirement for a future audit of the configuration;

WHEREAS Bell submitted that the following approach might be appropriate in this case: (1) written documentation of internal compliance procedures is prepared and made available to employees responsible for monitoring compliance; (2) written approval from an officer of Call For Less is required to authorize a change in the programming of the software routing tables; such written approval is kept on file for future inspection; and (3) monthly internal reviews of the switch programming and a sample review of Class of Service assignments are conducted to ensure continued compliance; the resulting monthly verification report is prepared by a switch technician and signed off by an officer of Call For Less; the reports would be kept on file for future inspection;

WHEREAS Bell submitted that in light of the lack of adequate control procedures as identified by the technical audit and subsequent submission, it recommends that interim approval be granted pending the establishment of appropriate control procedures to verify the ongoing accuracy of the Class of Service codes and VFG routing arrangement;

WHEREAS Bell submitted that final approval should be granted only after Call For Less has satisfied the Commission that a documented, auditable control procedure for verifying the service configuration on an ongoing basis is in place;

WHEREAS further, Bell submitted that given the nature of the service arrangements, the configuration should be subject to the possibility of future random audits;

WHEREAS by letter dated 26 September 1996, Call For Less filed a copy of its control procedures entitled "Procedure Used for Determining the Characteristics for Contribution and Non-Contribution Calls" used to determine the characteristics for contribution exemption and non-contribution calls;

WHEREAS by letter dated 22 October 1996, Bell stated that on the basis of the description provided by Call For Less, the internal control procedure appears to satisfy the requirement noted in Bell's suggested recommendation (1) above for the documentation of procedures in use;

WHEREAS Bell noted that with respect to suggested recommendations (2) and (3) above, Call For Less has not advised the Commission whether they have been implemented;

WHEREAS Bell stated that since the routing of calls to each VFG is controlled by the applicant through the use of customer-provided equipment, Bell maintains that such procedures are essential to satisfy the requirement that the initial Class of Service assignments remain unaltered, and to verify that the routing of calls within the Centrex system over contribution-exempt and contribution-bearing VFGs remains unchanged over time;

WHEREAS further, Bell submitted that, given the nature of the service arrangements, the configuration should be subject to the possibility of future random audits;

WHEREAS accordingly, Bell submitted that interim approval may be appropriate pending written confirmation by Call For Less that it has established satisfactory ongoing control procedures, including an internal monthly review of the configuration, to verify the ongoing accuracy of the Class of Service codes and VFG routing arrangement;

WHEREAS the Commission is of the view that final approval can be granted effective the date of application for the Oshawa Centrex system since Bell has provided carrier verification; and

WHEREAS the Commission is of the view that Call For Less' technical audit for the Centrex system in the Toronto exchange is acceptable (except for suitable control procedures) and that interim approval could be granted effective the date of application subject to the provision of suitable control procedures -

IT IS HEREBY ORDERED THAT:

1. The application for Oshawa is approved effective the date of application, based on carrier verification.

2. Interim approval is granted for Toronto, effective the date of application, with final approval subject to Call For Less filing, within 30 days, evidence that demonstrates that sufficient administrative controls are in place to provide a basis for future random audits.

3. Call For Less' Toronto configuration is subject to future random audits.

Allan J. Darling
Secretary General