WLNP
COMPLIANCE: TIPS FROM THE FRONTLINE
Susan St. John
As the May 24 deadline approaches for Tier 2 and Tier 3 carriers,
here’s a look at how to ensure a smooth implementation process.
The wireless local number portability (WLNP) deadline for providers in
the top 100 metropolitan statistical areas (MSAs) has come and gone. Some
found the passing of the November 24 date as nticlimactic as the passing
of midnight on December 31, 1999, while others continue to struggle. any
have only recently received their first valid porting request, and others
are still waiting. For providers outside the top 100 MSAs, May 24 is the
earliest date by which they are required to process porting requests.
However, substantial numbers of providers have received extensions and/or
are still awaiting a bona fide porting request to start their six month
deadline clock ticking. As such, some providers have yet to address the
issue while others are neck deep in the implementation process.
These variances are not surprising as the cost of a wireless LNP solution
is substantial enough to merit a thorough billing and OSS system review
(see Figure, p. 38). Typically, this analysis would be based on whether
or not the LNP upgrade will support your business for the next five years.
If it won’t, then a total system upgrade or conversion may be more
cost effective over the long run.
And in terms of time commitment, on average it takes a small to mid-sized
provider a minimum of 4,000 hours to complete research, analysis, planning,
development and quality assurance for a WLNP upgrade.
Waiting to implement a WLNP solution could increase the already hard-to-swallow
costs. Whether or not the May 24 deadline sticks, and regardless of when
a carrier receives the first valid porting request, either occurrence
should not trigger the start of this project. Waiting will force rushed
implementations, increase error rates, strain resources and result in
cost overruns. There are also the resulting fines. These factors aside,
the inability to process port-ins and port-outs could wind up costing
providers the ultimate price—their reputation. While the demand
for vendor solutions is just now picking up speed, the real onslaught
is a few months away.
Porting Costs
WLNP costs are considerable due to the numerous “touch points” of
the added mobile identification number (MIN) or international MSI (IMSI),
a non-dialable number required to track the home carrier. The home carrier
used to be identifiable by the mobile directory number (MDN), a dialable
number that is the number that becomes ported. There are the obvious costs
to modifying the code in legacy customer care and billing systems as well
as any provisioning and/or interfacing to pooling authorities, roamer
traffic clearinghouses and porting coordinators. Switches typically require
software upgrades—and sometimes hardware upgrades—in order
to accommodate the MIN. Often customer handsets must be upgraded as well
due to service compatibility requirements and, even for non-porting customers,
the need to store the MIN. Handset replacements can carry additional costs
related to trade-in programs, inventory and POS. An often overlooked cost
is that of the additional data storage space required for the expanded
usage record formats and for including the MIN on customer and service
order records and perhaps others.
There are also substantial soft costs of WLNP, which are most significant
in the areas of staffing, testing and training. In order to adequately
test, elaborate systems must be devised to replicate a wide variety of
porting scenarios (offhours, kiosks, wireline, etc.) as well as all intercarrier
connections, switches and other interfaces.
Thankfully, one thing that most drastically distinguishes Y2K from WLNP
is the ability for provider cost recovery. Since the FCC has left the
parameters for cost recovery largely in the hands of providers themselves,
consideration must be given as to who should be charged, how much and
for how long. The trend seems to be to charge all customers a small to
moderate amount to recover the overall cost of acquiring and implementing
the required functionality. Determining those costs can be a project in
itself. “Just getting our arms around the project and understanding
how the entire billing process will work is a considerable undertaking,” says
Larry Cowie, IT manager of Illinois Valley Cellular, a mobile provider
serving north central Illinois.
Project Analysis
Being proactive with all agreements relative to WLNP is
in a provider’s best interest and can reduce cost overruns later
on. These arrangements may include clearinghouses, service bureaus,
switch and handset manufacturers, as well as other carriers, software
vendors and service bureaus contracted to address affected systems.
Each relationship and agreement will require its own analysis, management,
negotiation, testing and implementation. Internal relationships are
also affected.
The scope of business and application processes affected by WLNP is so
broad that it is fair to say that nearly every area of your business operations
and your customer care and billing systems will be affected in some way.
In assessing your organization’s specific needs for automation,
data transfer, storage and interfaces, your project analysis should consider
the following:
1. Do Your Research
Obtain as much documentation as possible from all parties.
Then, actually digest it. Eric Morisette, billing administrator at Illinois
Valley Cellular, says “I was not prepared for the amount of research
required for this project. As a result, we were forced to change our
initial project goals to accommodate for the extra time. ”
Another detail related to documentation is ensuring that you have the
most current information. For example, an early version of a switch vendor’s
documentation incorrectly described the character length of a field. The
actual length changed in the final documentation and resulted in significant
time identifying the source of the error, verifying the correct details,
fixing and retesting. Identifying and resolving such discrepancies early
in your project will reduce your cost by reducing the amount and extent
of rework necessary. Many such details could have an enormous impact on
analysis, testing, documentation and training, depending on how far along
you have proceeded before discovering the discrepancy.
2. Project Management 101
While we all understand the extent to which traditional
project management procedures can ensure the success of any project,
it is also true that many organizations —in particular, smaller
ones—do not always have dedicated project managers. As the WLNP
implementation necessitates particular attention to this area, a brief
project management “hit” list might come in handy for many
providers.
•
Be proactive. You’ll definitely need extra time if you don’t
have it.
•
Stay on top of pooling and porting interfaces and switch
manufacturers. A delay with any of them can halt your project and cause
delays. For more information on number pooling, go to www.nationalpooling.com.
•
Eliminate as much assumption and ambiguity as you can.
•
Designate project liaisons on each side of each agreement
and hold regular team meetings throughout.
•
Share what you learn. Lack of this sharing can force you
into situations of relying on trial and error—possibly even as your
live implementation is underway.
•
Document everything. The time involved is much less than
to revisit the same matters repeatedly.
•
Conduct project retrospective meetings following going
live.
3.You Can’t Test Enough
Obtain real-life examples of data comparable to the data
that you will have to process following the live implementation. Mock-ups
are not adequate. You will not realize the invalidities of your expectations
by preparing the test data according to those expectations. Record and
field lengths, valid values lists, acceptability of nulls or blanks—all
of these have been found to differ from their descriptions in the documentation
and other guidance furnished by the entities that determine and administer
them. Another example is whether your switches will be able to record
MIN values for all call parties. Perhaps they won’t. Even when
attempted, this may not always be technically possible. It’s better
to account for this possibility within your design, if necessary, to
prevent the potential revenue drain that may occur if you don’t
find out until you flip the switch and then must scramble to determine
and implement a resolution.
Also furnish real-life data examples to others that your data will go
to, such as intercarrier settlement clearinghouses. Press them to apply
their actual processes to your test data. Simply looking over the data
and responding that it appears acceptable does not mean that it will successfully
pass through the actual rules and validity tests that will be applied.
Penalty fees, revenue delays and even revenue losses could otherwise result
at your live implementation depending on the time required to make corrective
modifications.
Port-in promotions should consider rebates, credits for termination fees
with the originating carrier and handset upgrades (which may be necessary
anyway). For port-outs, consider data capture and reporting functionality
so that you are able to quantify the information, evaluate trends and
set about wooing those customers back.
4.Talk to Your Peers
“
The single most valuable thing providers can do in the
face of WLNP is to get involved with industry organizations on the state
and national level,” says Judy Bruns, CEO of Valley Telecom Group,
which operates several telecom companies in Arizona and New Mexico. “Your
investment will be repaid several times over to you in the knowledge you
receive.” Morisette adds, “The contact I have with other providers
during TSI Telecommunication Services’ monthly conference call is
one of the best sources I have for knowledge I can directly apply to my
situation.”
Chasing May 24
While providers aren’t required to be fully compliant by May 24
if they didn’t receive a request to port by Nov. 24, waiting to
address the situation means betting against a potentially significant
profit sector. As such, many carriers choose the proactive path, not only
in seeking out compliance systems and agreements, but in shaping FCC decisions
that affect them so significantly.
Bruns of Valley Telecom Group has been very active petitioning the FCC
on behalf of rural carriers. However she, along with other members of
organizations such as the National Telecommunications Cooperative Association,
the Organization for the Promotion and Advancement of Small Telecommunication
Companies and others don’t stop long to celebrate small victories
such as the recent FCC extension of porting requirements for “2
percent LECs”—wireline carriers that serve fewer than 2 percent
of the nation’s subscriber lines, but still operate within the top
100 MSAs—from November to May.
“The rulings have been extremely vague overall in establishing
guidelines and responsible parties,” Bruns says. “Things like
defining ‘local calls’ in the wireless arena leave vast areas
of interpretation that threaten to cost ILECs large sums.”
Bruns adds that there are many occasions where there are no interconnect
agreements in a rural area. “If we get a port request to another
carrier who has no NXX numbers in the same rate center, what happens?
Currently, that would mean that any calls made by that customer would
be classified as toll calls. So who pays?”
Bruns and her colleagues have recently filed petitions at both the state
and federal levels for a stay on the order for May 24 compliance. As of
this writing, the May 24 deadline stands—albeit with an increasing
number of exceptions. According to Wireless Telecommunications Bureau
spokesperson Lauren Patrich, the FCC would review any request made for
an extension of WLNP compliance on a case-by-case basis. “Any provider
making their case to the FCC needs to address some basic principles. Generally,
that means showing the FCC that the purpose of the LNP rule would not
be served by applying it strictly in this particular case,” she
says. "Alternatively, a provider requesting a waiver would need to
show that, based on unique or unusual circumstances, applying the rule
to them would be inequitable, unduly burdensome, or there is no reasonable
alternative. The bottom line is that the FCC must find that the waiver
is in the public interest.
“Above all, the provider needs to explain how and when they will
ultimately meet the rule. A provider that doesn't include that explanation
in their argument is going to have a rougher road than one that does.”
Susan St. John is the WLNP project manager for CommSoft. She is responsible
for development and implementation projects that automate processes and
procedures associated with WLNP compliance. She can be reached at sue.stjohn@commsoft.net.
Information in this article comes from results of project analysis for
a large-scale, fixed-price contract for one of the 10 largest regional
wireless providers and from compliance projects currently underway at
Illinois Valley Cellular and Valley Telecom Group. To download a WLNP
whitepaper, go to www.commsoft.net/wnp.htm.
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