Applying Billing Credits Prospectively

Party's Position

NeuStar already has billed and collected payments from some carriers for the cost of implementing pooling in the 310 NPA. According to the new cost allocation principles adopted in the decision, some carriers will qualify for a billing credit equal to the difference between the amount the carrier was previously billed and the revised amount due based upon the carrier's pro rata share of the assigned numbers. NeuStar requests that the Commission clarify that NeuStar may apply the credit due to each carrier toward future billables incurred by that carrier within three months. NeuStar also asks the Commission to clarify that NeuStar will make no adjustments to the credit if a new service provider subsequently commences service in the NPA.

Discussion

We shall clarify the decision to state that NeuStar may apply the billing credit as an offset toward future billings otherwise due from a carrier within three months of the effective date of today's decision. Permitting NeuStar to apply the billing credit in this manner will yield a more administratively efficient outcome. We shall also clarify that the billing credit only applies to previously billed carriers and is a one-time-only credit to account for overcharges resulting from the prior method of billing of carriers in effect before D.00-07-022. NeuStar shall make no reallocations to the billing credit due to previously billed carriers if a new service provider subsequently begins service in the NPA subsequent to the effective date of D.00-07-022. The billing credit shall only be applied to those carriers that were billed for pooling costs prior to the effective date of D.00-07-022.