To be a viable player in telecommunications, the company must
be certified or registered with most Public Service Commissions ("Commission")
and the F.C.C. In some states, Commissions are aggressively seeking out companies
operating without certification. For example, the Florida Commission has a rule
that prohibits an underlying carrier from providing intrastate service to a reseller
that has not been certified.
Visiology takes a business approach to
the certification
process. Whenever possible, the recommended approach is to request the Commission
exempt the reseller from regulation. This reduces not only the initial certification
costs but also the long term costs associated with regulation. Once certified, tariffs
must be updated and reporting requirements must be met. Some reports are due on
an annual or quarterly basis while others are due monthly.
Because the
Visiology
consultants have an extensive background in telecommunications operations, we are
able to assist the reseller in the development of policy and procedures that will
meet the state requirements and also make good business sense. Where the reseller
has not established the formal procedures required in the tariff, Visiology consultants
offer various alternatives presenting the pros and cons of each. On occasion, we
also recommend changes to existing procedures to reduce operating expense, minimize
regulatory impact, or increase revenue.
A key element in the
Visiology approach
is staying in constant contact with members of the Commission staff. While most
state Commissions have written statutes, rules, and guidelines as to what's required
in the petitions and tariffs, it's the unwritten certification requirements that
can lengthen the certification process. Documents are individualized for each state
not only to meet the written requirements in that state but also to answer the additional
questions that are typically asked by staff member in subsequent data requests. Visiology offers a plan for completing the certification process. The responsibilities
of Visiology and the company under the plan are as follows:
Prepares the petition and letter that goes to the Commission for initial registration
or certification.
Prepares the initial tariff in the format required by each state commission with
the rules and regulations that are unique to that state. Minor changes are made
to the tariff without charge. Major changes, such as the addition of a new service
or rules for an additional carrier, are billed at $80 per hour.
All documents are delivered to the reseller in hard copy and on a WordPerfect
5.1 diskette (diskettes meet FCC requirements). Without diskette copies, the reseller
is unable to revise tariffs inhouse once certified.
Prepares an instruction letter with each filing indicating signature requirements,
number of copies to be filed, fees, and any special instructions.
Works with the attorney in those states that require local counsel submit the
certification documents. In order to reduce the billable attorney hours, Visiology
consultants prepare the documents. The attorney reviews the documents and files
them with the Commission. Visiology can recommend attorneys that have worked
well
with the Commission staff and other clients.
Serves as Commission contact during the certification process where
allowed.
Revises petition and tariff if requested by the attorney or Commission
staff.
Prepares response to "Data Request" from the Commission when
required.
Provides typical questions for hearings that the client will attend where local
counsel is not required.
Provides Visiology a point of contact for questions about the
company.
Completes a lengthy questionnaire that provides information about the company
and services.
Provides current service rates for all tariffed services in spreadsheet format
(Lotus or Quattro) or in WordPerfect 5.1 Tables.
Provides a liaison to the various state Commissions to answer questions regarding
the company, the petition, and/or tariff. The person assigned this responsibility
must be able to respond to "Data Requests" from the Commission in a timely
manner. If desired, Visiology will serve as liaison where allowed by the
Commission.
Reviews documents prior to mailing to Commission. Attachments such as
current
financial statements are added to documents by the reseller.
Signs documents and has documents notarized when appropriate.
Makes appropriate number of copies and mails signed documents to the
Commission.
Where required, checks for the filling fees are attached to the petitions.
Attends hearings in the states that require an officer or employee attend.
A key advantage of using Visiology is that the consultants are experienced in managing most functions within a telecommunications company. We understand the business implications of the information requested by the Commission. Visiology's philosophy is to consider the long term impact to the reseller and to make tariff implementation as painless as possible
Cost of certification / registration is significantly less expensive than using
traditional methods.
Emergency projects can usually be accommodated.
Visiology consultants consider all information provided as proprietary
and will
not share it with your competitors.
Visiology can offer a payment plan tailored to fit the reseller's cash
flow needs.
Visiology consultants have worked in and with start-ups and understand their special needs.
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Last update 8/9/02