OMB received a
large number of comments from various sectors of the
telecommunications industry and several state regulatory agencies.
This is a very contentious issue with parties offering a number of
valid criticisms and supporting views related to the FCC NPRM.
After reviewing the comments submitted to OMB, it is apparent that,
because this is a rulemaking and given the preliminary nature of
the proposals contained in this item, OMB must review this
collection upon release of the Report and Order related to CC
Docket 98-170. OMB strongly encourages the FCC not to adopt an
approach that imposes undue burden on wireless providers and small
wireline services -- and urges flexibility be given to small
companies that may experience significant cost and managerial
issues related to implementation of any billing requirements. The
FCC should also allow companies sufficient time to address their
Year 2000 efforts as well as modifying their billing systems to
meet any new requirements. OMB recommends that the FCC make a
concerted effort to work with industry to establish voluntary
guidelines in lieu of mandatory requirements that restrict the
ability of firms to tailor their billing to meet the needs of
customers. The FCC and states should cooperate to minimize
conflicting or duplicative billing requirements. Comments indicate
a general agreement that: a) new charges or services need to be
easily identifiable on bill; b) definitions of services and other
terms are difficult to reach and could be counterproductive; c)
more information, including point of contact toll free numbers, for
service providers or billing agents needs to be included in billing
materials; d) materials should be clear, concise, and relatively
simple; e) the FCC must account for costs of any changes to bills
that will be passed on to consumers in making decisions; f) CMRS
and other wireless firms that provide services only to businesses
should be exempt from most new requirements that would be imposed
on wireline carriers; g) every effort should be made so that
billing standards are uniform across the nation; h) reseller
information should be included (in a same format as service
provider information); and i) where possible, market-based
solutions should be adopted unless there is conclusive evidence
that there is either a failure or the FCC cannot adequately enforce
its current rules and therefore must enact regulations that affect
billing practices. OMB believes these are reasonable
recommendations that should be included in this rulemaking. The FCC
shall submit this collection to OMB again following release of the
Report and Order, prior to requiring compliance with any new
billing format regulations.
Inventory as of this Action
Requested
Previously Approved
12/31/2001
12/31/2001
1,800
0
0
185,400
0
0
9,000,000
0
0
The Commission proposes to make
consumer's telephone bills easier to read and understand. Telephone
bills do not provide necessary information in a user-friendly
format. As a result, consumers are experiencing difficulty in
understanding their bills, in detecting fraud on their telephone
bills, in comparing carrier rates to get the best value for
themselves, and in resolving billing disputes.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Truth-in-Billing Format -- CC Docket No. 98-170 (Proposed Rule)