1. OSS Reconciliation Billing December 2004 Project Operation Support System (OSS) Cost Recovery Billing TOMMY WILLIAMS, SR. PRODUCT MANAGER TITANIA ALEXANDER, PRODUCT MANAGER BRYAN WELKER, PRODUCT MANAGER January 27, 2005

2. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 2 Overview Effective November 16, 2004, BellSouth implemented mechanized billing of Operation Support Systems (OSS) Charges for cancelled Sup 01 Local Service Requests. Effective December 1, 2004, the BellSouth OSS team implemented the OSS Reconciliation billing initiative to recover billable charges for Sup 01 Local Service Requests (LSR). The billing covers billable periods beginning November 1, 2002 and continuing through November 16, 2004 pursuant to each CLEC’s Interconnection Agreement and the applicable statute of limitations.

3. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 3 Frequently Asked Questions 1.Why wasn’t this charge applied before? 2.Has BellSouth changed it’s billing practices? 3.How are the charges calculated? 4.How does BellSouth determine whether or not the customer cancelled the order? 5.Where should inquiries be sent? 6.Why wasn’t data provided in advance of billing? 7.When requesting data, what will I need to provide? 8.Does BellSouth intend to apply this method of billing in the future? 9.When will this method of billing be applied? 10.How will Late Payment Charges (LPC) be handled? 11.What will the Grace Period be? 12.What other reconciliation efforts is BellSouth planning to implement? 13.Is BellSouth at Parity with Retail? 14.Who should I contact if I disagree with the charge?

4. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 4 1. Why wasn’t this charge applied previously? In an effort to balance billing efficiencies with project demands, a business decision was made to combine the reconciliation efforts with the billing initiative. Our chief concern was to ensure the applicability of the charges and to manage the implementation of the charges based on the Interconnection Agreements in place.

5. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 5 2. Has BellSouth changed it’s billing practices? No, BellSouth has not changed it’s billing practices with regard to the billing of applicable OSS charges. Charges are billed based on service dates and bill periods. In a reconciliation effort, billing is applied for services rendered for which an applicable charge was not assessed.

6. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 6 3. How are the charges calculated? OSS charges vary by state and OSS plan type offerings. Customers may select Regional or State Specific rate offerings via their Interconnection Agreements. Based on this selection, the appropriate billing is applied.

7. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 7 4. How does BellSouth determine whether or not the customer cancelled the order? Requests for cancellations are noted as Sup 1 or Sup 01. This indicates an order for cancellation per customer request. Requests may be made electronically or manually.

8. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 8 5. Where should inquiries be sent? Inquiries for detail data relative to the reconciliation effort may be directed to: ICS. Reconciliation @BellSouth.com.

9. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 9 6. Why wasn’t data provided in advance of billing? In prior reconciliation efforts, we were able to provide the data on a customer accessible website. After monitoring such site for two years, it was determined that the costs associated with this service were not justified since less than 10% of the customers actually utilized the site. We are currently in the process of establishing a more efficient way of distributing the details to customers. In the interim, we offer customers the option of receiving data via CD until a better solution is achieved.

10. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 10 7. When requesting data what will I need to provide? To expedite data responses, you will be asked to submit the following: The BAN(s) (billing account numbers) listed on your company’s bill; and Verification of your company’s billing address and contact information.

11. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 11 8. Why did BellSouth apply this method of billing ? This method of billing was applied because it was the most effective and efficient means of reconciling customer billing.

12. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 12 9. When will this method of billing be applied? Reconciliation began with the December 1, 2004 billing period.

13. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 13 10. How will Late Payment Charges (LPC) AND Grace periods be handled? Late Payment Charges (LPCs) will be handled business as usual. Carrier Notification Letter (SN91084260) dated November 1, 2004, provided advance notice and instructions for customers to obtain the underlying data supporting BellSouth’s reconciliation of the charges. This allowed customers additional time to request and review the data before the charges appeared on their December 2004 bill. Therefore, LPCs will be billed if payment is withheld as per the customer’s contract. After the customer has requested and reviewed the data, and should the customer believe they have a legitimate billing dispute, the customer should follow the appropriate process for submitting a billing dispute. Customer’s should refer to their contract language and may also refer to the websites listed below for information on submitting Billing Disputes. Continued on the next slide..

14. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 14 continued….. 10. How will Late Payment Charges (LPC) Grace be handled? Once a billing dispute is resolved, if the dispute is resolved in favor of the CLEC, the LPC and interest, where applicable will be adjusted (based on the portion of the dispute amount that is credited). If the dispute is found in favor of BellSouth, the LPC’s and interest, where applicable, remain as billed.

15. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 15 11. What will the Grace period be? There is no special grace period that applies to this initiative.

16. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 16 12. What other reconciliation efforts is BellSouth planning to implement? BellSouth proactively posts Carrier Notifications within the required time frame.

17. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 17 13. Is BellSouth at Parity with Retail? This is not a parity issue. Billing is governed by the negotiated language in the Interconnection Agreements.

18. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 18 14. Who should I contact if I disagree with the charge? For billing disputes, please contact the BellSouth Billing & Collections Group. http://www.interconnection.bellsouth.com/forms/html/billing &collections.html You may submit a billing dispute electronically using the following website address: http://apps.interconnection.bellsouth.com/Ebar/bar.JSP The Billing Adjustment Request (BAR) form (RF 1461) cab be located at the following website address: www.interconnection.bellsouth.com/forms/html/billing&collections.html www.interconnection.bellsouth.com/forms/html/billing&collections.html Information on Dispute Resolution can also be found in the BellSouth CLEC Billing Guide located at : www.interconnection.bellsouth.com/guides/html/understanding_bill.html

19. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 19 SUMMARY Reconciliation efforts began with the December 1, 2004 billing periods. These charges were applied pursuant to each CLEC’s Interconnection Agreement and the applicable statute of limitations. These charges will be applied during the normal billing cycle on a going forward basis.

20. Interconnection Services Private/Proprietary: Not for Use or Disclosure Outside BellSouth Except Under Written Agreement 20