In Part 3 of this series regarding further regulation of ICS in Alabama (Part 1 posted on 10/22/13 and Part 2 posted on 10/23/13), I have focused on the issues of Monthly Statements, the Alabama specific web page, and Quarterly Reports that have been proposed in the Alabama Commission’s Order.
Monthly statements
The Alabama rules would require monthly statements of call activity to be provided either on paper or electronically, to all customer account holders at no charge. This requirement would apply to all debit, prepaid and direct billed customer accounts. Very specific and fairly substantial amounts of information would be provided in the monthly account statements.
There was no discussion identifying any current problem with providing call detail to end users. The order cites Rule T-5c which addresses bill format and content requirements. The rule discusses and has historically been applied to local presubscribed service. It would appear that the current proposal is to apply this rule to one type of transient service provider. Rule T-5c has not historically been imposed on either ICS or operator service providers.
The list of required information takes up most of a page. Is such microscopic regulation truly necessary to serve the public interest? After all, some detainees may spend no more than a day or two in a facility and may make only a few phone calls. It is likely that ICS providers who provide direct billing to certain end users already provide call detail. But is it workable or necessary to require ICS providers who do not have billing systems to mail and/or post all such call activity on a monthly basis?
If monthly call detail is required to be posted online for all debit and prepaid traffic, would there be any additional expense or complexity associated with FCC Customer Proprietary Network Information privacy compliance in terms of procedures, account log ins, passwords, and other security requirements?
If mandatory creation and mailing of monthly statements are imposed, would compliance represent a significant increase in costs of service? Should an end user be able to opt out? In some situations, the ICS provider may not have valid contact information for an account holder. How should that be handled?
Would it be reasonable to establish different standards or make exceptions for facilities that typically house longer term inmates vs. those that serve more as local holding facilities? DOC facilities vs. county or city jails?
Ultimately, would it be more efficient to ensure that the ICS rules require provision of call detail and any other information upon request and at no charge… and allow carriers to provide it in the most efficient manner possible?
Alabama specific web page
The order proposes that a separate Alabama-specific web page be established. There is no discussion as to why this is desirable or necessary. No other state, and not even the FCC, has suggested doing this.
The information specified is useful. Given that, is it already being provided on ICS websites? Much of the information that the order proposes be included in a separate Alabama page is not unique to Alabama, but is applicable in all states served.
Quarterly Reports
Everyone knows that reporting obligations go hand in hand with regulatory authority. The order contemplates reports that would divulge local, intrastate and interstate MOUs and corresponding revenue, by facility, each quarter. There is no discussion in the order as to why this is needed or to what use it would be put.
It would seem that some explanation identifying a current problem that creates the need for such data would be in order. Parties could perhaps address any Commission concerns directly. Facility specific data may be considered proprietary. Are there any Industry concerns with such a reporting requirement?
See a sample of our Institutional Rates Summary
