Technologies Management, Inc. has been preparing tariffs for all types of carriers for over 25 years. We don’t recall that any client ever thought of their tariffs as a revenue generator. Let’s face it, although tariffs can be useful, they fall squarely in the overhead category.
Most telecommunications companies have a complement of professionals to manage and file their tariffs. They have salaries, benefits, and their own overhead that make up most of the cost of managing the tariffs. As more and more jurisdictions eliminate, reduce or limit tariffs, that cost goes away. Right? Well, not really. Some carriers choose to maintain tariffs everywhere they can. (There are good reasons for that – but that’s a separate discussion.) There are also still a number of jurisdictions that require tariffs or filed price lists. And there are regulatory agencies, like the FCC, that do not require tariffs, but do require public posting of rates, terms, and/or conditions. So the overhead associated with tariffs has declined over time, but it is still not eliminated.
This creates another problem, how do you justify adding personnel to this department to replace personnel who have left for one reason or another? And when the department loses scale, how do you handle time sensitive projects that are beyond the capacity of the remaining department?
The loss of knowledgeable personnel who cannot be replaced not only reduces peak output capacity, it can significantly impact the quality of work…creating even more work for the few remaining resources downstream. Picking up a poorly prepared or documented tariff to make changes to it can double or quadruple the work time associated with preparing the next filing.
Of course, TMI advocates for outsourcing tariffs to us to save time and money, while gaining flexibility. But absent that solution, for those of you remaining in the trenches with little help, we recommend some management techniques that have proven to save time and money:
- Set and adhere to standards for format, letters, and (to the extent possible) text. No matter what you say, I promise you that most tariff departments don’t do this very well. It considerably shortens the time it takes to prepare a filing and reduces unwelcome surprises for the next filing. Not to mention making it easier to train new tariff personnel or to outsource a big project.
- Detariff – where is makes sense for you to so do so.
- Use tariff standards (see No. 1 above) for managing price lists that are to be filed or posted.
- Get your files onto your corporate network in a location accessible by legal, regulatory, management, marketing and sales. If you outsource, get copies of your files in native format (e.g. Word) from your vendor and onto your corporate network or permanent electronic archive. Re-creating a history of filings is difficult and time consuming if they are not readily accessible. There are some tariff vendors who will only provide copies of tariffs to their clients in .pdf format. This is not acceptable and may prove costly at some inconvenient time.
- Track the time it takes each individual to prepare and file tariffs and revisions. If one person takes half a day to prepare a check sheet and another person takes a quarter of an hour, the opportunities for cost savings become obvious.
- Create a schedule for each filing project, noting the status of each element by jurisdiction. Don’t overlook posting of price lists, e-filing obligations, filing fees, etc.
- Request filing fees for projects well in advance. Create a budget line item for filing fees along with all other expenses. Don’t forget to increase the budget to compensate for increased fees or to decrease it where detariffing has eliminated the necessity.
- Request a copy of the customer notice before the tariff language is finalized. This can save last minute fire drills and notice changes. Be sure all relevant parties stay informed about ongoing notice requirements where detariffing has taken place.
- Document and quantify back office processes, including copying, shipping, web filing, Internet posting, filing fee processing, transmittal letters, scanning and filing of receipted transmittals, tracking, archiving. This will improve scalability, training, and budgeting.
- Calendar upcoming compliance filings and look for opportunities to combine with substantive changes.
These processes won’t turn your tariffs into profit centers, but they will help keep the tariff budget in check by enabling you to get more done with fewer resources.
See TMI’s Timely Tip from 8/25/14.