AT&T said it “does not regard the manner in which it handles operator-assisted collect calls via TRS from inmates as subject to the rate requirements” in the FCC’s ICS Order. However, it is concerned that inmates or their families “may claim that the definition of ICS” includes the operator service provided by AT&T and other carriers when a deaf inmate makes a TRS call and interstate long distance charges apply.
AT&T notes that the FCC’s Order describes ICS as “the offering of interstate calling capabilities from an inmate telephone. An inmate telephone, according to the order, means a telephone instrument or other device capable of initiating telephone calls set aside by authorities of a correctional institution for use by inmates. Arguably, these elements are present in AT&T’s provision (by tariff) of operator assisted collect calls.”
AT&T then goes on to describe how it handles TRS calls from correctional institutions:
“Pursuant to contract with state authorities, AT&T provides TRS service in eight states plus the District of Columbia. Often times, but not always, the TRS Communications Assistant (CA) can see that the call has originated from a detention facility. For security, operator services practices limit inmate calling to collect calls. Upon receiving the call, the inmate can direct the CA to forward the call to any interexchange carrier on the carrier of choice list. The CA in the states where AT&T provides the service is an AT&T employee. If the inmate selects AT&T as the IXC for the call, the CA then functions as the operator service provider and the called party will be charged at the tariffed rate for the call, which is higher than the rate cap for a collect call specified in the ICS order. AT&T interexchange collect calling services are not limited to inmates only; anyone making the same type of TRS collect call will be treated and charged in the same manner.”
The filing also includes call flow diagram.