JSI is aware that some clients have received a notice from AT&T concerning the expiration of their current Wholesale/Commercial Operator Service and Directory Assistance (OS/DA) agreements. Companies have several options in handling this notice: renew the agreement, terminate the agreement, or find another OS/DA provider.

Renew Agreement: JSI has compared the new generic agreement/form to the baseline existing agreement. The new agreement removes certain operator services that are in older agreements, including: calling card, collect, third number billed, busy line verification, and busy line interrupt. According to AT&T, retail end users have stopped using these services, rendering them obsolete. If you currently offer any of these services and renew your agreement with AT&T, you are are required to submit a Section 214 Discontinuance of Domestic Services filing with the FCC (more details are below).

Other terms, including pricing, are substantially the same so there is no additional cost to renew the agreement. It is AT&T’s intent to avoid negotiation of any of the terms in the new agreements. It asks carriers who are interested in retaining AT&T as their underlying OS/DA provider to complete a request form and return it via email or fax by the proposed termination date of May 1, 2015.

Terminate the Agreement: Use of operator services has significantly declined over the years. Some LECs may not want to continue to offer OS/DA services. There are no FCC rules that would prevent a LEC from discontinuing OS/DA services, but there may be some state requirements. If you want to discontinue OS/DA, check your state rules to ensure there are not consequences. If you decide to discontinue service, you will need to submit a Section 214 Discontinuance of Domestic Services filing with the FCC. In addition, customers should be notified of changes since a “0” dialed call will no longer be routed to an operator after the service is discontinued.

Change OS/DA Carriers: If your company would like to continue to offer OS/DA services or is restricted from terminating OS/DA service, you can change the carrier performing the services. There are several other companies that perform the service. Be sure that the new provider offers all the services that you want to continue. If any of the services are discontinued, a 214 discontinuance notice must be filed with the FCC.

Section 214 Discontinuance and Impairment of Service Filing: When a carrier discontinues a telecommunications service it must file a Section 214 application with the FCC, as well as apply to the state to discontinue the services and remove the services from their tariff. These filings generally require customer notice, and can require up to 90 days for processing. Therefore, carriers may need to begin drafting these filings immediately to coordinate with AT&T’s planned service termination date. The 214 process, however, will not be complete by the May 1, 2015, date.

If you have received a request from AT&T and would like JSI’s assistance in understanding the OS/DA service agreement revisions, please contact Dee Dee Longenecker in the Texas office at 512-338-0473. For assistance with drafting Section 214 Discontinuance of Domestic Services filings or required state filings, please contact Valerie Wimer in the Maryland office at 301-459-7590.

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