Workshop to Review the Oftel Metering and Billing Standard: Summary of Meeting held at Oftel on 26 June 2000

Meeting attendees
Introduction
1st workshop session
2nd workshop session

Attendees:

Peter Walker, Oftel
Bill Hawkins, Oftel
Hilary Anderson, Oftel
Malcolm Davies, Oftel
Ben Wrigley, Kingston Telecommunications Laboratories
Danny Dutt, BT Cellnet
David Lang, Cable & Wireless
Keith Taylor, Vodafone
Elisa Szabo, Vodafone
Julia Stutfield , Vodafone
Geoff Marsh, Kingston Communications Ltd
Louise Hampton, Orange
Judith Galpin, Orange
Lisa Whittle, Energis
Martin Fell, Ericsson
Matthew Arnold, NTL
Mike Inman, BSI
Paul Ebling, BABT
Richard Bowyer, BT
Vernon Kitay, One2one
William Reed, Cellcom
Barry Cartman, Consultant

The meeting began at 10 a.m. with a welcome and introduction from Peter Walker, Oftel Director, Technology.

The agenda, as circulated before the meeting, was tabled together with the statement of Objectives for the Revised Oftel Metering and Billing Standard and notes of the workshop and seminar held at Oftel on 18^th April (previously published on the Oftel web site).

The objectives, not previously published in this form, were reviewed by Peter Walker and are reproduced below for reference:

These objectives are taken from the Oftel Statement Ensuring telephone bills are accurate - A statement on the review of the Oftel Meter Approval Scheme for Public Telecommunications Operators published on 17 February 2000.

• The revised standard must cover metering and billing as an end-to-end process.

• Reference to PTOs must be broadened to include Systemless Service Providers.

• Elements of the Service Usage Specification such as the practicalities of call timing must be included.

• A suitable method of re-focussing on individual billing accuracy must be included.

• All chargeable elements of rental, discount schemes and supplementary services must be included.

• Application to NTS, VPN, Centrex and leased lines must be enabled.

• Elements of overall revenue integrity and revenue assurance shall be retained though possibly relaxed.

• The revised standard should be written in a 'technology neutral' manner.

• The objective is to enhance consumer protection.

• One measure of success would be the establishment of an ongoing reduction in the levels of billing complaint received by operators and Oftel alike.

In summary, PW stated that Oftel intended to create a fair and practical standard that had increased capacity for approval of metering and billing systems across the whole industry.

PW then invited questions from the working group in relation to the above objectives.

1st Workshop session

DL (C&W) asked whether Oftel had considered that a greater reliance on self-regulation could be effective and to what extent this was already happening in the market. PW replied that there was no evidence of this happening in practice judging by the increasingly high levels of billing complaint recorded across the industry.

The notes of the meeting of 18^th April were then reviewed and a summary follows of the principal matters arising:

The issue of the inclusion of charges for SMS text calls was raised by KT of Vodafone stating that currently some 5 million SMS calls per day were being made over the network.

PW stated that any obligation to include all data transmission services within the scheme would require a change to the PTO licence conditions on metering and billing but that if the industry was agreeable then SMS calls could be included in the scheme under the materiality rule.

It was agreed that good will write-offs for unallocated calls held in suspense could be considered as good commercial practice and that guidelines to allow these issues to be dealt with in a consistent manner may need to be elevated into the revised standard.

After a short break the second workshop session began with a presentation by Paul Ebling (BABT) centred around a number of key questions that BABT had addressed in setting out proposals for a revised standard.

New terminology introduced by the revised BABT draft and the revised figures for accuracy were explained. PE highlighted that the requirements for metering and billing accuracy had been combined into one single measure for the end-to-end process and that the figures for accuracy had been accordingly restated to reflect this.

The BABT presentation was followed by a presentation by Mike Inman of BSI of his proposals for revision of the standard based on internal documents already circulating within BSI. The BSI standard and associated comprehensive list of abbreviations and definitions had also been circulated to the working group just before the meeting.

It was then agreed that open discussion of the questions raised in the BABT presentation would be beneficial. The following is a summary of the BABT questions and the agreements reached by consensus at the meeting:

The BABT proposal, to take all these chargeable events together, was endorsed.

There was broad agreement that these should be combined together and covered by an overall end-to-end figure. It was recognised that Mobile ISPs may have areas of difficulty with re-pricing of wholesale provision.

PW stated that it was sensible to include SMS with voice for mobile if materiality exceeds 5%. However with large corporations other data services charges may be significant e.g. frame relay. GM (KCL) and others stated that customers expect all services on one bill.

Definition of materiality rule – PW said it was the same as recorded in the 18th April meeting notes, namely that it should be set on a product by product basis where 5% or more of the total customer base were taking the product. PW also restated that he would take 5% materiality as a suitable threshold for inclusion of data services such as SMS. PW proposed that residential and business consumers should be treated separately and that Oftel would define the relevant markets.

The inclusion of the call duration and time of day tolerances within the revised standard was agreed.

Discussion of the reliability issue developed into consideration of how to make allowance for hardware or network failure such as during switch failure and switch restart.

It was agreed that the method for dealing with short breaks in transmission and outages should be declared in published tariffs – particularly applicable to mobile calls.

It was agreed that relaxation of the under billing allowance in the standard could alleviate the problem. The only limiting factors to the extent of such relaxation would then be protection against anti-competitive behaviour and attention to dependencies on accuracy in the supply chain.

It was agreed that thresholds should be set to determine how to deal with disruptions to call records during network failures.

It was agreed that there should be asymmetry between the accuracy requirements for under billing and over billing. Ratios between 5:1 and 10:1 were thought to be appropriate.

It was suggested that concerns that the proposed relaxation in the under billing allowance would adversely impact the wholesale network to Service Provider relationship could be addressed by the agreement of appropriate contract terms between the parties.

BABT's proposal was agreed, namely that following proper definitions for published tariffs and previously agreed tariffs these should be taken as the point of reference for measurement of accuracy.

It was agreed as per the BABT slides that equipment/signals/data flows on which another party is dependent would be included in the scope of the revised standard.

It was also agreed that areas clearly beyond management control would be excluded.

Under this question the process of how to deal with the Oftel requirement for significant improvement in the confidence in the accuracy of individual bills was raised.

It was felt that as most PTOs are already doing quite extensive checking and sampling of individual bills as part of their internal billing management systems then the revised standard should concentrate on the extension and approval of these existing processes rather than on the introduction of an additional sampling process. It was also agreed that inclusion of consumer complaint data should be included in this overall process.

PW proposed that PTOs should declare their own complaints data for comparison with Oftel data and that all PTOs should do sample checks on individual bills.

It was noted that having an approved Quality Management System does not guarantee fitness for purpose or compliance with any accuracy requirements. Elements of current BABT process documentation namely BABT 600 which addresses the interpretation of the ISO 9001: 1994 Quality Management Standard and assessment of the PTO's QMS would need to be included.

It was agreed that the presentation of the revised Oftel Standard in conformance with the BS 0-3:1997 as per BABT proposals was acceptable.

It was agreed that bills should be rendered in a timely manner. It was also noted under this heading that the BABT proposal also included a reference to the writing off of charges not presented within a defined period of months from the date of the charge being incurred.

It was agreed that the date/time stamping and call duration tolerances need to be included in the revised standard and that rules applied for call rounding should also be called for in the standard and in published tariffs.

Richard Bowyer (BT) stated that he supported the BABT proposals for revised accuracy figures as realistic and achievable – based on his analysis of past performance across BT network.

The general proposal to allow accuracy requirements for metering and those for billing to be asymmetrical was agreed, as this would allow recognition that metering in modern networks is likely to be more accurate. PW proposed that a ratio of 10:1 was appropriate as this would require that metering accuracy be 10 times better than billing accuracy for a given measure.

With reference to the absolute accuracy requirements, a concern was expressed that for the smaller PTOs, the most difficult area of compliance was the accuracy requirement for 'value of over metering' set at less than 1 part in 100,000 of the value of total usage in the current Oftel Standard. It was stated that compliance with this measure might become increasingly difficult because the value of individual calls is steadily falling in line with overall price reductions. These points were noted and the inclusion of a suitable fixed value as an alternative measure was agreed to take account of such circumstances.

Following further general discussion on the issue of absolute accuracy requirements, numerical revisions were proposed that broadly reflected the consensus views of the working group. It was agreed that these revised figures would be incorporated in the next draft of the revised standard.

Finally Peter Walker asked for the working group to consider how best to include PRE PAY and the top up process in the revised scheme. PW posed the question, was the 'top up' a third process in addition to metering (or logging) and billing ? PW reminded the working group that he had already invited mobile PTOs to submit discussion papers on this subject and that he expected they would want to respond.

Peter Walker also stated that it was now unlikely that Oftel would ask any additional PTOs to make submissions for approval under the current scheme, though those PTOs currently approved would be expected to maintain their approved status under the current scheme until the revised scheme was launched. Suitable arrangements for transition from the current scheme to the revised scheme would be agreed with the parties concerned.

It was agreed that further comments on the revision of the Oftel Standard should be gathered and sent by the Working Group by email for collation and inclusion in the next draft of the revised standard which would then be circulated in early August.

The date of next meeting of the Working Group has been set for 15^th September.

END OF NOTES